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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Addition u/s 40A - Cash expenditure exceeding the threshold of Rs. 20,000/- - The appellant/assessee argued that the payments made through supervisors, who were employees of the assessee, to individual workers did not exceed Rs. 20,000/- each. Therefore, Section 40A(3) of the Act, which disallows certain expenditures not made by crossed cheque or bank draft, should not apply. - The High Court found that the supervisors were indeed employees of the appellant, as evidenced by the assessing officer's lack of dispute on this matter. Therefore, the payments made through supervisors were considered payments by the appellant. As these payments did not exceed Rs. 20,000/- to any individual worker and were made through agents of the appellant, the second proviso to Section 40A(3) applied, and the disallowance was not justified.
Addition u/s 40A - Cash expenditure exceeding the threshold of Rs. 20,000/- - The appellant/assessee argued that the payments made through supervisors, who were employees of the assessee, to individual workers did not exceed Rs. 20,000/- each. Therefore, Section 40A(3) of the Act, which disallows certain expenditures not made by crossed cheque or bank draft, should not apply. - The High Court found that the supervisors were indeed employees of the appellant, as evidenced by the assessing officer's lack of dispute on this matter. Therefore, the payments made through supervisors were considered payments by the appellant. As these payments did not exceed Rs. 20,000/- to any individual worker and were made through agents of the appellant, the second proviso to Section 40A(3) applied, and the disallowance was not justified.
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