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 upheld deletion of interest expense disallowance where assessee provided interest-free advances while having interest-bearing loans. The advances were given with commercial expediency for business ventures with profit expectations. Tribunal noted sufficient interest-free funds were available with assessee exceeding outstanding amounts. Regarding provision for expenses, ITAT confirmed that under mercantile accounting system, provision for known expenses is mandatory even without actual payment. The scientific basis for year-end provisions was accepted as routine practice following accounting principles. Previous years' treatment of both interest-free advances and provision for expenses supported assessee's position. Revenue's appeal dismissed, ruling in favor of assessee on both grounds of commercial expediency and accounting methodology.
ITAT upheld deletion of interest expense disallowance where assessee provided interest-free advances while having interest-bearing loans. The advances were given with commercial expediency for business ventures with profit expectations. Tribunal noted sufficient interest-free funds were available with assessee exceeding outstanding amounts. Regarding provision for expenses, ITAT confirmed that under mercantile accounting system, provision for known expenses is mandatory even without actual payment. The scientific basis for year-end provisions was accepted as routine practice following accounting principles. Previous years' treatment of both interest-free advances and provision for expenses supported assessee's position. Revenue's appeal dismissed, ruling in favor of assessee on both grounds of commercial expediency and accounting methodology.
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