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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Disallowance of prior period expenses pertaining to expenditure crystallized or details received after completion of earlier years' audits. Genuineness not doubted, remitted to AO for verification of non-claim in prior years. Addition of depreciation on estimated 10% cost towards stamp duty/registration charges on properties with pending lease/sub-lease execution remitted to AO for de novo verification as per jurisdictional High Court order. Revenue de-recognition issue remanded to AO based on Supreme Court decision and application u/s 158A(1). Administrative charges on Andrews Ganj Project disallowed based on High Court ruling of no accrual of income. Grants-in-aid expenditure allowed as wholly and exclusively for business. Revenue recognition of loan fees on realization basis upheld based on certainty of realization, C&AG directives, and High Court decision. Disallowance u/s 14A rejected as no exempt income claimed. Correct TDS credit remitted to AO for factual verification. Financial charges written off allowed as deduction based on High Court decision. Prior period expenses disallowed due to lack of evidence of crystallization. Disallowance u/s 14A limited to 1% of dividend income pre-Rule 8D. CSR expenses pre-April 1, 2015 allowed based on High Court ruling. Prior period expenditure.
Disallowance of prior period expenses pertaining to expenditure crystallized or details received after completion of earlier years' audits. Genuineness not doubted, remitted to AO for verification of non-claim in prior years. Addition of depreciation on estimated 10% cost towards stamp duty/registration charges on properties with pending lease/sub-lease execution remitted to AO for de novo verification as per jurisdictional High Court order. Revenue de-recognition issue remanded to AO based on Supreme Court decision and application u/s 158A(1). Administrative charges on Andrews Ganj Project disallowed based on High Court ruling of no accrual of income. Grants-in-aid expenditure allowed as wholly and exclusively for business. Revenue recognition of loan fees on realization basis upheld based on certainty of realization, C&AG directives, and High Court decision. Disallowance u/s 14A rejected as no exempt income claimed. Correct TDS credit remitted to AO for factual verification. Financial charges written off allowed as deduction based on High Court decision. Prior period expenses disallowed due to lack of evidence of crystallization. Disallowance u/s 14A limited to 1% of dividend income pre-Rule 8D. CSR expenses pre-April 1, 2015 allowed based on High Court ruling. Prior period expenditure.
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