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 ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
The ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
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