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, a contractor or developer, was initially denied deduction u/s 80IA(4) by the Assessing Officer, citing the retrospective amendment introduced by the Finance Act, 2009, which required the assessee to be the owner of the property as a developer. However, the ITAT held that the assessee qualified as a developer within the meaning of Section 80-IA and was eligible for the deduction under Sub-section (4). The High Court upheld the concurrent findings of the CIT (Appeals) and the Tribunal, stating that the assessee was awarded a contract for full-fledged development of a new infrastructure facility at an airport, involving financial and entrepreneurial risk, thus qualifying as a developer eligible for the deduction.
The assessee, a contractor or developer, was initially denied deduction u/s 80IA(4) by the Assessing Officer, citing the retrospective amendment introduced by the Finance Act, 2009, which required the assessee to be the owner of the property as a developer. However, the ITAT held that the assessee qualified as a developer within the meaning of Section 80-IA and was eligible for the deduction under Sub-section (4). The High Court upheld the concurrent findings of the CIT (Appeals) and the Tribunal, stating that the assessee was awarded a contract for full-fledged development of a new infrastructure facility at an airport, involving financial and entrepreneurial risk, thus qualifying as a developer eligible for the deduction.
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