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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Allowance of standard deduction u/s 24(a), deduction for actual repairs, and deduction of accumulated income u/s 11(2) in the case of a charitable trust claiming exemption u/s 11. The Tribunal held that standard deduction of rental income at 30% u/s 24A cannot be allowed while computing income eligible for exemption u/s 11. Regarding actual repairs, the AO was directed to allow deduction for actual repairs and maintenance expenditure incurred before arriving at income available for accumulation u/s 11(2) or taxable income. Concerning accumulation u/s 11(2), the assessee failed to provide details on availability of funds for specified investments u/s 11(5), and the Tribunal rejected the ground for accumulation deduction. The summary covers the critical issues using relevant legal terminology in a concise manner.
Allowance of standard deduction u/s 24(a), deduction for actual repairs, and deduction of accumulated income u/s 11(2) in the case of a charitable trust claiming exemption u/s 11. The Tribunal held that standard deduction of rental income at 30% u/s 24A cannot be allowed while computing income eligible for exemption u/s 11. Regarding actual repairs, the AO was directed to allow deduction for actual repairs and maintenance expenditure incurred before arriving at income available for accumulation u/s 11(2) or taxable income. Concerning accumulation u/s 11(2), the assessee failed to provide details on availability of funds for specified investments u/s 11(5), and the Tribunal rejected the ground for accumulation deduction. The summary covers the critical issues using relevant legal terminology in a concise manner.
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