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 held that deduction of interest u/s 57 against interest income must be substantiated by the assessee. Interest expenditure must be incurred for earning interest income. In this case, interest on delayed sale payment is not connected to interest expenditure on loans for business purchases. Interest income is under 'income from other sources,' while interest expenditure is linked to 'capital gain.' Lack of evidence on TDS deduction or actual payment renders the claim inadmissible. The CIT(A)'s decision was upheld, dismissing all grounds raised by the assessee.
The ITAT held that deduction of interest u/s 57 against interest income must be substantiated by the assessee. Interest expenditure must be incurred for earning interest income. In this case, interest on delayed sale payment is not connected to interest expenditure on loans for business purchases. Interest income is under 'income from other sources,' while interest expenditure is linked to 'capital gain.' Lack of evidence on TDS deduction or actual payment renders the claim inadmissible. The CIT(A)'s decision was upheld, dismissing all grounds raised by the assessee.
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