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 14A r.w.r.8D - AO mandation to record dis-satisfaction with the correctness of the Assessee's claim regarding expenditure related to exempt income - The Assessee contested the disallowance, arguing that the Assessing Officer did not provide valid reasons for rejecting its explanation. The High Court emphasized the necessity for the AO to record dissatisfaction with the Assessee's claim regarding expenditure related to exempt income and provide cogent reasons for such dissatisfaction. Upon analysis of the AO's assessment order, the Court found deficiencies in the recording of dissatisfaction, indicating a lack of proper application of mind. Consequently, the High Court validated the decision of the ITAT, affirming that the AO failed to adequately justify the disallowance made by the Assessee.
Addition u/s 14A r.w.r.8D - AO mandation to record dis-satisfaction with the correctness of the Assessee's claim regarding expenditure related to exempt income - The Assessee contested the disallowance, arguing that the Assessing Officer did not provide valid reasons for rejecting its explanation. The High Court emphasized the necessity for the AO to record dissatisfaction with the Assessee's claim regarding expenditure related to exempt income and provide cogent reasons for such dissatisfaction. Upon analysis of the AO's assessment order, the Court found deficiencies in the recording of dissatisfaction, indicating a lack of proper application of mind. Consequently, the High Court validated the decision of the ITAT, affirming that the AO failed to adequately justify the disallowance made by the Assessee.
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