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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ITAT quashed revision order under s.263 regarding ESOP expenses claimed by assessee as deduction. Assessee provided comprehensive documentation including TP report under s.92D(1), employee details, valuation reports, and accounting treatment compliant with ICAI guidelines. ESOP costs were properly recorded as salary compensation, with parent company MakeMyTrip (Mauritius) shares listed on NASDAQ. AO conducted adequate verification before allowing deduction, examining grant price calculations and vesting schedules. ITAT found PCIT's revision grounds untenable as AO had performed necessary inquiries. The tribunal confirmed ESOP expenses as legitimate business deduction, noting their role in employee retention and motivation.
ITAT quashed revision order under s.263 regarding ESOP expenses claimed by assessee as deduction. Assessee provided comprehensive documentation including TP report under s.92D(1), employee details, valuation reports, and accounting treatment compliant with ICAI guidelines. ESOP costs were properly recorded as salary compensation, with parent company MakeMyTrip (Mauritius) shares listed on NASDAQ. AO conducted adequate verification before allowing deduction, examining grant price calculations and vesting schedules. ITAT found PCIT's revision grounds untenable as AO had performed necessary inquiries. The tribunal confirmed ESOP expenses as legitimate business deduction, noting their role in employee retention and motivation.
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