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 deals with various issues related to income tax assessment. The Tribunal directed the CIT(A) to verify the details and reconcile the tax deducted at source, allowing the assessee an opportunity to furnish documentary evidence. Regarding software license fees, following its previous order, the Tribunal treated it as revenue expenditure and not capital expenditure. Interest received on bank fixed deposits was held as business income and not income from other sources, relying on a High Court decision. The Tribunal upheld the CIT(A)'s order restricting the disallowance u/s 14A to 0.5% of the average investment and directed the AO to compute it after considering the suo moto disallowance made by the assessee.
The case deals with various issues related to income tax assessment. The Tribunal directed the CIT(A) to verify the details and reconcile the tax deducted at source, allowing the assessee an opportunity to furnish documentary evidence. Regarding software license fees, following its previous order, the Tribunal treated it as revenue expenditure and not capital expenditure. Interest received on bank fixed deposits was held as business income and not income from other sources, relying on a High Court decision. The Tribunal upheld the CIT(A)'s order restricting the disallowance u/s 14A to 0.5% of the average investment and directed the AO to compute it after considering the suo moto disallowance made by the assessee.
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