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...
ITAT ruled on multiple issues in a tax dispute. TPO adjustments regarding Northstar Health Care were deleted following prior precedent. For drug sales pricing adjustments, ALP recomputation was ordered. Provision for rebates written back was deleted based on statutory benefit principles. Addition for restructuring-related provisions was confirmed due to rate differential concerns. Job work charges addition was deleted as genuineness was established. For R&D deduction under s.35(2AB), claim denied due to missing Form 3CL but alternative relief under s.37/32 permitted subject to proper bifurcation. FCCB premium redemption expense disallowed under s.40(a)(i) for non-deduction of TDS, to be allowed in year when TDS is deducted.
ITAT ruled on multiple issues in a tax dispute. TPO adjustments regarding Northstar Health Care were deleted following prior precedent. For drug sales pricing adjustments, ALP recomputation was ordered. Provision for rebates written back was deleted based on statutory benefit principles. Addition for restructuring-related provisions was confirmed due to rate differential concerns. Job work charges addition was deleted as genuineness was established. For R&D deduction under s.35(2AB), claim denied due to missing Form 3CL but alternative relief under s.37/32 permitted subject to proper bifurcation. FCCB premium redemption expense disallowed under s.40(a)(i) for non-deduction of TDS, to be allowed in year when TDS is deducted.
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