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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Deduction u/s 35(1)(ii) disallowed by AO based on Investigation Wing's report alleging bogus donations receipts issued by institutions. ITAT held AO did not make independent inquiry to prove applicability of Investigation Wing's view to assessee. No material brought to disprove assessee's evidence regarding donations paid. No proof of cheque amount being ploughed back as cash to assessee. Subsequent withdrawal of recognition u/s 35(1)(ii) not a bar for allowing deduction for earlier donations. Assessee's claim u/s 35(1)(ii) allowed for both years. Assessee appeal allowed.
Deduction u/s 35(1)(ii) disallowed by AO based on Investigation Wing's report alleging bogus donations receipts issued by institutions. ITAT held AO did not make independent inquiry to prove applicability of Investigation Wing's view to assessee. No material brought to disprove assessee's evidence regarding donations paid. No proof of cheque amount being ploughed back as cash to assessee. Subsequent withdrawal of recognition u/s 35(1)(ii) not a bar for allowing deduction for earlier donations. Assessee's claim u/s 35(1)(ii) allowed for both years. Assessee appeal allowed.
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