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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT quashed the reassessment proceedings u/s 148 as being bad in law, holding that the reasons recorded did not demonstrate any failure by the assessee to disclose true facts, and it was a case of "change of opinion" or "review of the assessment order" which is impermissible. The ITAT allowed the claim for deduction of reinsurance premiums paid to non-residents, depreciation on UPS at 60%, and payments made to motor vehicle dealers for services rendered. It upheld the disallowance of depreciation on projectors and addition of long-term insurance premiums received. The ITAT allowed deduction for IBNR and IBNER provisions, and held Section 14A disallowance inapplicable to insurance companies. It remitted the issue of disallowance of UPR for re-adjudication, deleted the addition u/s 14A for computing book profits, and dismissed the claim for deduction of education cess.
The ITAT quashed the reassessment proceedings u/s 148 as being bad in law, holding that the reasons recorded did not demonstrate any failure by the assessee to disclose true facts, and it was a case of "change of opinion" or "review of the assessment order" which is impermissible. The ITAT allowed the claim for deduction of reinsurance premiums paid to non-residents, depreciation on UPS at 60%, and payments made to motor vehicle dealers for services rendered. It upheld the disallowance of depreciation on projectors and addition of long-term insurance premiums received. The ITAT allowed deduction for IBNR and IBNER provisions, and held Section 14A disallowance inapplicable to insurance companies. It remitted the issue of disallowance of UPR for re-adjudication, deleted the addition u/s 14A for computing book profits, and dismissed the claim for deduction of education cess.
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