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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Rental income correctly classified as "income from house property" rather than "income from business" despite composite rent including amenities charges. TDS deducted appropriately u/ss 194I and 194C. Assessee maintained separate books, audited financials bifurcating rental income and service charges. AO accepted this treatment for multiple years. CIT(A) erred in overlooking evidence. Directed AO to consider rental income under "income from house property" and amenities charges under "income from business", allowing deductions. Disallowance of interest expenses for lack of nexus to business remitted to AO for re-examination after providing opportunity to assessee to substantiate availability of own funds as per Reliance Utilities case. Disallowance of brought forward book loss adjustment against book profits u/s 115JB remitted to AO with direction to provide opportunity to assessee to substantiate. Disallowance of interest expenses despite availability of own funds remitted to AO for verification after giving assessee an opportunity.
Rental income correctly classified as "income from house property" rather than "income from business" despite composite rent including amenities charges. TDS deducted appropriately u/ss 194I and 194C. Assessee maintained separate books, audited financials bifurcating rental income and service charges. AO accepted this treatment for multiple years. CIT(A) erred in overlooking evidence. Directed AO to consider rental income under "income from house property" and amenities charges under "income from business", allowing deductions. Disallowance of interest expenses for lack of nexus to business remitted to AO for re-examination after providing opportunity to assessee to substantiate availability of own funds as per Reliance Utilities case. Disallowance of brought forward book loss adjustment against book profits u/s 115JB remitted to AO with direction to provide opportunity to assessee to substantiate. Disallowance of interest expenses despite availability of own funds remitted to AO for verification after giving assessee an opportunity.
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