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 case pertains to rectification of mistake u/s 154 regarding the eligibility of exemption u/s 10(17A) for the award money received from BCCI. The assessee, a sportsman, had initially filed the award amount as taxable income from other sources, despite it being exempt u/s 10(17A) as clarified by CBDT Circular No. 2/2014. The ITAT held that since the assessee is not a professional and the award was received in the capacity of a sportsman, the amount is exempt from tax. The mistake in filing the return appears bonafide. Following the precedent in Mr. Chanrkant Gulabrao Borde vs. ITO, the assessee is entitled to relief, and the CIT(A)'s order is unsustainable. The assessee's appeal is allowed.
The case pertains to rectification of mistake u/s 154 regarding the eligibility of exemption u/s 10(17A) for the award money received from BCCI. The assessee, a sportsman, had initially filed the award amount as taxable income from other sources, despite it being exempt u/s 10(17A) as clarified by CBDT Circular No. 2/2014. The ITAT held that since the assessee is not a professional and the award was received in the capacity of a sportsman, the amount is exempt from tax. The mistake in filing the return appears bonafide. Following the precedent in Mr. Chanrkant Gulabrao Borde vs. ITO, the assessee is entitled to relief, and the CIT(A)'s order is unsustainable. The assessee's appeal is allowed.
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