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 Income Tax Appellate Tribunal (ITAT) has adjudicated on various issues concerning deductions u/ss 80IA(4), 14A, and 35D. Regarding Section 80IA(4) deduction, the ITAT found the Commissioner of Income Tax (Appeals) [CIT(A)]'s observations inadequate to determine the assessee's eligibility as a developer. Hence, the matter was remanded to the CIT(A) for fresh adjudication after examining relevant evidence and providing an opportunity of being heard. Concerning Section 14A disallowance, the ITAT held that no disallowance u/r 8D(2)(b) was warranted as the assessee had sufficient interest-free funds. However, the disallowance u/r 8D(2)(c) was upheld, subject to the CIT(A)'s fresh adjudication on its impact on Section 80IA(4) deduction. Regarding Section 35D disallowance, the ITAT upheld the CIT(A)'s order in part and remanded the matter for fresh adjudication after considering the assessee's evidence and following the principles of natural justice.
The Income Tax Appellate Tribunal (ITAT) has adjudicated on various issues concerning deductions u/ss 80IA(4), 14A, and 35D. Regarding Section 80IA(4) deduction, the ITAT found the Commissioner of Income Tax (Appeals) [CIT(A)]'s observations inadequate to determine the assessee's eligibility as a developer. Hence, the matter was remanded to the CIT(A) for fresh adjudication after examining relevant evidence and providing an opportunity of being heard. Concerning Section 14A disallowance, the ITAT held that no disallowance u/r 8D(2)(b) was warranted as the assessee had sufficient interest-free funds. However, the disallowance u/r 8D(2)(c) was upheld, subject to the CIT(A)'s fresh adjudication on its impact on Section 80IA(4) deduction. Regarding Section 35D disallowance, the ITAT upheld the CIT(A)'s order in part and remanded the matter for fresh adjudication after considering the assessee's evidence and following the principles of natural justice.
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