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 High Court addressed the issue of deduction u/s 80-IC (2) (a) for a company manufacturing Pan Masala. The company's product was considered excluded for deduction due to the Thirteenth Schedule provisions. The Court noted the specific exclusion of tobacco and related products in Part B of the Schedule for certain states. As the company was located in an area specified by the Central Board of Direct Taxes, the Court found that the product, which did not contain tobacco, was eligible for the deduction. It emphasized that the legislature's omission of Pan Masala in the relevant part of the Schedule precluded its inclusion under the deduction disqualifications. Ultimately, the Court ruled in favor of the company, allowing the deduction u/s 80-IC (2) (a) (i) and Section 80-IC (3) of the Income Tax Act, 1961.
The High Court addressed the issue of deduction u/s 80-IC (2) (a) for a company manufacturing Pan Masala. The company's product was considered excluded for deduction due to the Thirteenth Schedule provisions. The Court noted the specific exclusion of tobacco and related products in Part B of the Schedule for certain states. As the company was located in an area specified by the Central Board of Direct Taxes, the Court found that the product, which did not contain tobacco, was eligible for the deduction. It emphasized that the legislature's omission of Pan Masala in the relevant part of the Schedule precluded its inclusion under the deduction disqualifications. Ultimately, the Court ruled in favor of the company, allowing the deduction u/s 80-IC (2) (a) (i) and Section 80-IC (3) of the Income Tax Act, 1961.
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