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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Reopening of assessment u/s 147 - Exemption of dividend income and the allowability of short-term capital loss - The Tribunal ruled in favor of the appellant, quashing the reassessment proceedings on the grounds of improper approval and lapse of the prescribed time period. - Regarding the exemption of dividend income and the allowability of short-term capital loss, the Tribunal found the appellant's transactions to be genuine and based on publicly available information. It concluded that the appellant fulfilled the conditions specified in the Income Tax Act, making them eligible for the claimed exemptions. Therefore, the disallowance of exemption for dividend income and the denial of the short-term capital loss claimed were overturned.
Reopening of assessment u/s 147 - Exemption of dividend income and the allowability of short-term capital loss - The Tribunal ruled in favor of the appellant, quashing the reassessment proceedings on the grounds of improper approval and lapse of the prescribed time period. - Regarding the exemption of dividend income and the allowability of short-term capital loss, the Tribunal found the appellant's transactions to be genuine and based on publicly available information. It concluded that the appellant fulfilled the conditions specified in the Income Tax Act, making them eligible for the claimed exemptions. Therefore, the disallowance of exemption for dividend income and the denial of the short-term capital loss claimed were overturned.
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