Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Accrual of income - Taxability of notional interest income credited by the assessee in his profit and loss account as per the requirement of Indian Accounting Standards - The assessee, a public limited company, had credited interest-free loans to its subsidiary and accounted for "notional interest" in its books. The Revenue challenged this, arguing for its inclusion in taxable income. However, the Appellate Tribunal, after considering submissions from both sides and referring to relevant precedent, ruled in favor of the assessee. It held that since there was no contractual obligation for the debtor to pay interest, the notional interest income did not accrue and should not be taxed.
Accrual of income - Taxability of notional interest income credited by the assessee in his profit and loss account as per the requirement of Indian Accounting Standards - The assessee, a public limited company, had credited interest-free loans to its subsidiary and accounted for "notional interest" in its books. The Revenue challenged this, arguing for its inclusion in taxable income. However, the Appellate Tribunal, after considering submissions from both sides and referring to relevant precedent, ruled in favor of the assessee. It held that since there was no contractual obligation for the debtor to pay interest, the notional interest income did not accrue and should not be taxed.
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