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 assessee claimed deduction for compensation paid to farmers for acquiring mining rights, which was an allowable expenditure. The Assessing Officer allowed the expenditure over 20 years and made an addition. The CIT(A) allowed the assessee's appeal, relying on the Supreme Court's decision in M/s Reliance Petro Products Pvt. Ltd., holding that it was not a case of furnishing inaccurate particulars of income, and penalty u/s 271(1)(c) of the Income Tax Act was not leviable. The assessee did not furnish inaccurate particulars, and the expenditure was allowed on a deferred basis. The ITAT, in Simplex Pharma (P) Ltd. and Onicra Credit Rating Agency of India Ltd., had deleted the penalty levied u/s 271(1)(c) on deferred revenue expenditure. The ITAT concurred with the CIT(A)'s findings and dismissed the revenue's ground.
The assessee claimed deduction for compensation paid to farmers for acquiring mining rights, which was an allowable expenditure. The Assessing Officer allowed the expenditure over 20 years and made an addition. The CIT(A) allowed the assessee's appeal, relying on the Supreme Court's decision in M/s Reliance Petro Products Pvt. Ltd., holding that it was not a case of furnishing inaccurate particulars of income, and penalty u/s 271(1)(c) of the Income Tax Act was not leviable. The assessee did not furnish inaccurate particulars, and the expenditure was allowed on a deferred basis. The ITAT, in Simplex Pharma (P) Ltd. and Onicra Credit Rating Agency of India Ltd., had deleted the penalty levied u/s 271(1)(c) on deferred revenue expenditure. The ITAT concurred with the CIT(A)'s findings and dismissed the revenue's ground.
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