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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Disallowance u/s 14A read with Rule 8D - Suo moto disallowance by assessee upheld, disallowance restricted to Rs. 2,00,000 for the year, following HT Media Ltd. decision. Disallowance u/s 14A while computing book profits u/s 115JB - Actual expenditure of Rs. 2,00,000 disallowed, as per Vireet Investments P Ltd. decision. Expenditure on paintings allowed as revenue expenditure, following Wipro Ltd. decision, being for aesthetic purpose and better environment. Disallowance on account of currency burnt in fire - Issue restored to Assessing Officer for fresh adjudication considering additional evidence of advance received from scrap dealer, with direction to allow loss if advance burnt, and avoid double taxation in subsequent year if disallowed.
Disallowance u/s 14A read with Rule 8D - Suo moto disallowance by assessee upheld, disallowance restricted to Rs. 2,00,000 for the year, following HT Media Ltd. decision. Disallowance u/s 14A while computing book profits u/s 115JB - Actual expenditure of Rs. 2,00,000 disallowed, as per Vireet Investments P Ltd. decision. Expenditure on paintings allowed as revenue expenditure, following Wipro Ltd. decision, being for aesthetic purpose and better environment. Disallowance on account of currency burnt in fire - Issue restored to Assessing Officer for fresh adjudication considering additional evidence of advance received from scrap dealer, with direction to allow loss if advance burnt, and avoid double taxation in subsequent year if disallowed.
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