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 considered the issue of exemption u/s 11 regarding the non-utilization of 85% of grants-in-aid received during the year. The Tribunal found that the assessee, a statutory body, followed proper accounting procedures treating grants as liabilities until utilized by implementing agencies. The Assessing Officer's objection to the accounting method was deemed incorrect as the assessee's treatment of income and expenditure was consistent and valid. The principle of res judicata was discussed, emphasizing that each tax year is independent. The Tribunal upheld the assessee's compliance with accounting standards and rejected the Revenue's claim that the investment in equity shares violated section 13(1)(d). The Revenue's appeal was dismissed.
The Appellate Tribunal considered the issue of exemption u/s 11 regarding the non-utilization of 85% of grants-in-aid received during the year. The Tribunal found that the assessee, a statutory body, followed proper accounting procedures treating grants as liabilities until utilized by implementing agencies. The Assessing Officer's objection to the accounting method was deemed incorrect as the assessee's treatment of income and expenditure was consistent and valid. The principle of res judicata was discussed, emphasizing that each tax year is independent. The Tribunal upheld the assessee's compliance with accounting standards and rejected the Revenue's claim that the investment in equity shares violated section 13(1)(d). The Revenue's appeal was dismissed.
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