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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Regarding the deduction u/s 80IA, the Tribunal affirmed that ground handling and cargo handling services provided by the assessee were covered within the scope of 'developing, operating and maintaining' an airport, thereby entitling the assessee to claim the deduction. Additionally, the Tribunal upheld the incorporation of the assessee company as initiated by the Government of India, satisfying the conditions for claiming the deduction. On the disallowance of provision for concession fee, the Tribunal concluded that the provision was made on a certain basis and did not create a debt in favor of the concessionaire, thereby supporting the decision to delete the disallowance by the CIT(A).
Regarding the deduction u/s 80IA, the Tribunal affirmed that ground handling and cargo handling services provided by the assessee were covered within the scope of 'developing, operating and maintaining' an airport, thereby entitling the assessee to claim the deduction. Additionally, the Tribunal upheld the incorporation of the assessee company as initiated by the Government of India, satisfying the conditions for claiming the deduction. On the disallowance of provision for concession fee, the Tribunal concluded that the provision was made on a certain basis and did not create a debt in favor of the concessionaire, thereby supporting the decision to delete the disallowance by the CIT(A).
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