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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Income tax case involving disallowance of expenses incurred by a company for maintaining a guest house. The legal ownership of the guest house was with the company during the relevant assessment year. The company incurred expenditure towards maintenance of the guest house for business purposes. The Tribunal held that the expenditure was for business purposes and should be allowed as a deduction. It cited the principle that it is for the assessee to decide whether an expenditure should be incurred in the course of business. The Supreme Court's decision in Sasoon J. David case was relied upon, which held that voluntary expenditure incurred for promoting business and earning profits is deductible. The Tribunal directed the Assessing Officer to allow the guest house maintenance expenditure and delete the additions made. The case was decided in favor of the assessee company.
Income tax case involving disallowance of expenses incurred by a company for maintaining a guest house. The legal ownership of the guest house was with the company during the relevant assessment year. The company incurred expenditure towards maintenance of the guest house for business purposes. The Tribunal held that the expenditure was for business purposes and should be allowed as a deduction. It cited the principle that it is for the assessee to decide whether an expenditure should be incurred in the course of business. The Supreme Court's decision in Sasoon J. David case was relied upon, which held that voluntary expenditure incurred for promoting business and earning profits is deductible. The Tribunal directed the Assessing Officer to allow the guest house maintenance expenditure and delete the additions made. The case was decided in favor of the assessee company.
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