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 several key issues. Firstly, on Transfer Pricing (TP) adjustment, it found errors in the CIT(A)'s decision as rectification was only sought for professional fees, not ESOP, leading to a flawed dismissal. The Tribunal directed a fresh review by the CIT(A) with proper consideration and opportunity for the assessee. Secondly, on comparable selection, the CIT(A) erred by only addressing the validity of comparables, neglecting other raised issues. The Tribunal ordered a reevaluation by the CIT(A) on all grounds. Lastly, on disallowance u/s 14A, the Tribunal remitted the matter back to CIT(A) for a thorough review of dividend income and related expenditures, emphasizing due process. Additionally, on disallowance u/s 14A for MAT purposes, the Tribunal found the CIT(A)'s order lacking and mandated a new review with proper consideration and hearing for the assessee.
The Appellate Tribunal addressed several key issues. Firstly, on Transfer Pricing (TP) adjustment, it found errors in the CIT(A)'s decision as rectification was only sought for professional fees, not ESOP, leading to a flawed dismissal. The Tribunal directed a fresh review by the CIT(A) with proper consideration and opportunity for the assessee. Secondly, on comparable selection, the CIT(A) erred by only addressing the validity of comparables, neglecting other raised issues. The Tribunal ordered a reevaluation by the CIT(A) on all grounds. Lastly, on disallowance u/s 14A, the Tribunal remitted the matter back to CIT(A) for a thorough review of dividend income and related expenditures, emphasizing due process. Additionally, on disallowance u/s 14A for MAT purposes, the Tribunal found the CIT(A)'s order lacking and mandated a new review with proper consideration and hearing for the assessee.
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