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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Banks are required to maintain a Statutory Liquidity Ratio (SLR) by purchasing government securities. RBI guidelines categorize securities as Held-to-Maturity (HTM), Available-for-Sale (AFS), and Held-for-Trading (HFT). For AFS and HFT securities, the broken period interest paid during acquisition is allowed as a deduction, as these are treated as stock-in-trade. However, for HTM securities, the treatment depends on whether they are held as investments or stock-in-trade, based on the facts of each case. If held as investments, the broken period interest is capitalized; if held as stock-in-trade, it is allowed as a deduction. The Supreme Court upheld the Tribunal's decision that when securities are treated as stock-in-trade, the broken period interest cannot be considered capital expenditure and must be allowed as a deduction. The court clarified that the benefit of deduction is available for securities held as trading assets but not for those held as investments.
Banks are required to maintain a Statutory Liquidity Ratio (SLR) by purchasing government securities. RBI guidelines categorize securities as Held-to-Maturity (HTM), Available-for-Sale (AFS), and Held-for-Trading (HFT). For AFS and HFT securities, the broken period interest paid during acquisition is allowed as a deduction, as these are treated as stock-in-trade. However, for HTM securities, the treatment depends on whether they are held as investments or stock-in-trade, based on the facts of each case. If held as investments, the broken period interest is capitalized; if held as stock-in-trade, it is allowed as a deduction. The Supreme Court upheld the Tribunal's decision that when securities are treated as stock-in-trade, the broken period interest cannot be considered capital expenditure and must be allowed as a deduction. The court clarified that the benefit of deduction is available for securities held as trading assets but not for those held as investments.
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