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 ITAT upheld the assessee's claim for expenses paid to contractors for loading and unloading, as supported by banking transactions and TDS deductions. Contractors confirmed providing labor, and cash withdrawals were for labor payment. The AO's claim of ex-employees as contractors was justified for reliable labor supply. The allegation of unexplained investment in land purchase was dismissed as the deal did not materialize. Sales-tax subsidy was deemed a capital receipt, requiring quantification by the AO. The matter of 14A provisions was remanded to the AO for further examination.
The ITAT upheld the assessee's claim for expenses paid to contractors for loading and unloading, as supported by banking transactions and TDS deductions. Contractors confirmed providing labor, and cash withdrawals were for labor payment. The AO's claim of ex-employees as contractors was justified for reliable labor supply. The allegation of unexplained investment in land purchase was dismissed as the deal did not materialize. Sales-tax subsidy was deemed a capital receipt, requiring quantification by the AO. The matter of 14A provisions was remanded to the AO for further examination.
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