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 dismissed the revenue's appeals and upheld the CIT(A)'s order deleting the additions made by the AO. The assessee provided invoices and documents proving the purchases, which were accepted in the remand report. The 10% disallowance of other expenses was deleted after the AO verified the invoices. The disallowance of foreign exchange loss was rejected, relying on precedents that the revenue cannot question the commercial expediency of business expenditure if the nexus with business is established.
The ITAT dismissed the revenue's appeals and upheld the CIT(A)'s order deleting the additions made by the AO. The assessee provided invoices and documents proving the purchases, which were accepted in the remand report. The 10% disallowance of other expenses was deleted after the AO verified the invoices. The disallowance of foreign exchange loss was rejected, relying on precedents that the revenue cannot question the commercial expediency of business expenditure if the nexus with business is established.
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