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 reviewed a case involving the revision u/s 263 regarding the accrual of interest income on contributions made by the assessee towards Core Settlement Guarantee Fund. The CIT held that the AO erred in not examining the taxability of the accrued interest income before allowing its application in the accounts. The ITAT found that the contributions to the fund were under the control of ICCL and created to safeguard investors' interests, with any income accrued being exempt u/s 10(23EE) of the Act. The ITAT determined that the AO had collected and verified relevant information, and the PCIT did not demonstrate how the income earned by ICCL was chargeable to tax in the assessee's hands. The ITAT concluded that while the AO's order may be considered erroneous, it did not meet the condition of being prejudicial to revenue, ruling in favor of the assessee.
The ITAT reviewed a case involving the revision u/s 263 regarding the accrual of interest income on contributions made by the assessee towards Core Settlement Guarantee Fund. The CIT held that the AO erred in not examining the taxability of the accrued interest income before allowing its application in the accounts. The ITAT found that the contributions to the fund were under the control of ICCL and created to safeguard investors' interests, with any income accrued being exempt u/s 10(23EE) of the Act. The ITAT determined that the AO had collected and verified relevant information, and the PCIT did not demonstrate how the income earned by ICCL was chargeable to tax in the assessee's hands. The ITAT concluded that while the AO's order may be considered erroneous, it did not meet the condition of being prejudicial to revenue, ruling in favor of the assessee.
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