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 CIT(A)'s decision to restrict TP adjustment on guarantee commission to 0.2% for one financial year, finding TPO's 0.77% adjustment unjustified. The ITAT also supported CIT(A)'s deletion of 0.25% mark-up without basis. Regarding ESOP expenses, ITAT agreed with CIT(A) that discount on ESOP shares was deductible u/s 37(1) as it was not a capital expenditure. Disallowance u/s 14A was rejected as no exempt income was earned, following precedents that disallowance cannot exceed exempt income. Revenue's appeal was dismissed.
The ITAT upheld the CIT(A)'s decision to restrict TP adjustment on guarantee commission to 0.2% for one financial year, finding TPO's 0.77% adjustment unjustified. The ITAT also supported CIT(A)'s deletion of 0.25% mark-up without basis. Regarding ESOP expenses, ITAT agreed with CIT(A) that discount on ESOP shares was deductible u/s 37(1) as it was not a capital expenditure. Disallowance u/s 14A was rejected as no exempt income was earned, following precedents that disallowance cannot exceed exempt income. Revenue's appeal was dismissed.
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