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 addressed multiple issues in the case. Firstly, it ruled that disallowance u/s 40A(2)(b) can only be made in relation to "related parties," not unrelated ones. The disallowance of interest expenses to unrelated parties was deemed incorrect. Secondly, the Tribunal found that the assessing officer's adoption of 11% as the "fair market value" of interest lacked proper justification and comparable cases. Thirdly, the addition u/s 68 for unsecured loans lacked thorough inquiry by the assessing officer, and the documentary evidence provided by the assessee was considered adequate. The Tribunal decided in favor of the assessee on all these grounds.
The Appellate Tribunal addressed multiple issues in the case. Firstly, it ruled that disallowance u/s 40A(2)(b) can only be made in relation to "related parties," not unrelated ones. The disallowance of interest expenses to unrelated parties was deemed incorrect. Secondly, the Tribunal found that the assessing officer's adoption of 11% as the "fair market value" of interest lacked proper justification and comparable cases. Thirdly, the addition u/s 68 for unsecured loans lacked thorough inquiry by the assessing officer, and the documentary evidence provided by the assessee was considered adequate. The Tribunal decided in favor of the assessee on all these grounds.
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