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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The Appellate Tribunal considered various issues. Firstly, on disallowance u/s. 14A r.w. Rule 8D(ii), it was held that no disallowance of interest expenditure was warranted as the company had sufficient interest-free funds to source its investments in exempt income-yielding shares. The Tribunal referred to relevant case law to support this decision. Secondly, on addition towards various expenses, the Tribunal upheld the CIT(Appeals) decision to allow deduction under section 37 of the Act as the Assessing Officer failed to provide justifiable reasons for disallowance. Lastly, on addition u/s 68 for unexplained loan transaction, the Tribunal concurred with the CIT(Appeals) that the loan raised from a lender company was not unexplained cash credit as the identity of the lender was proven. The Tribunal dismissed the revenue's appeals on all grounds.
The Appellate Tribunal considered various issues. Firstly, on disallowance u/s. 14A r.w. Rule 8D(ii), it was held that no disallowance of interest expenditure was warranted as the company had sufficient interest-free funds to source its investments in exempt income-yielding shares. The Tribunal referred to relevant case law to support this decision. Secondly, on addition towards various expenses, the Tribunal upheld the CIT(Appeals) decision to allow deduction under section 37 of the Act as the Assessing Officer failed to provide justifiable reasons for disallowance. Lastly, on addition u/s 68 for unexplained loan transaction, the Tribunal concurred with the CIT(Appeals) that the loan raised from a lender company was not unexplained cash credit as the identity of the lender was proven. The Tribunal dismissed the revenue's appeals on all grounds.
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