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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Section 80-I deduction was denied for the unexpired period when a partnership firm was converted into a private limited company carrying on the same activity. However, based on the Supreme Court's decision in Chetak Enterprises and the Allahabad High Court's ruling in Prisma Electronics, the benefit of Section 80-I deduction should be allowed for the unexpired period even after the conversion from a partnership firm to a private limited company, as long as the same activity is continued. The appeals were allowed, entitling the assessee to the Section 80-I deduction and consequent benefit for the unexpired period.
Section 80-I deduction was denied for the unexpired period when a partnership firm was converted into a private limited company carrying on the same activity. However, based on the Supreme Court's decision in Chetak Enterprises and the Allahabad High Court's ruling in Prisma Electronics, the benefit of Section 80-I deduction should be allowed for the unexpired period even after the conversion from a partnership firm to a private limited company, as long as the same activity is continued. The appeals were allowed, entitling the assessee to the Section 80-I deduction and consequent benefit for the unexpired period.
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