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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Shares allotted at premium based on valuation report following DCF method. AO rejected report without pointing errors. ITAT held valuation not an exact science, cannot be done with arithmetic precision. Shares subscribed by outside investor, a reputed corporate group, not a related party. Hence, no infirmity in CIT(A) order deleting addition u/s 56(2)(viib). Disallowance u/s 36(1)(iii) on interest expenditure deleted by CIT(A) as zero coupon debentures were consideration for transfer of assets, not investment. ITAT upheld CIT(A)'s view. Interest-free deposit given had sufficient own funds, no disallowance u/s 36(1)(iii) warranted as per Bombay High Court ruling. Assessee's appeal allowed on this issue.
Shares allotted at premium based on valuation report following DCF method. AO rejected report without pointing errors. ITAT held valuation not an exact science, cannot be done with arithmetic precision. Shares subscribed by outside investor, a reputed corporate group, not a related party. Hence, no infirmity in CIT(A) order deleting addition u/s 56(2)(viib). Disallowance u/s 36(1)(iii) on interest expenditure deleted by CIT(A) as zero coupon debentures were consideration for transfer of assets, not investment. ITAT upheld CIT(A)'s view. Interest-free deposit given had sufficient own funds, no disallowance u/s 36(1)(iii) warranted as per Bombay High Court ruling. Assessee's appeal allowed on this issue.
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