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 ruled on three key issues in a capital gains case. The Tribunal determined Rs. 10,85,28,620 as full sale consideration for land rights relinquishment, rejecting assessee's claim for net amount adjustment against outstanding loans due to absence of explicit stipulation in resolutions. On Section 54F deduction, ITAT allowed relief following Karnataka HC precedent that investment of entire consideration within stipulated period suffices, even if construction remains incomplete. However, legal charges, advance maintenance, and certain registration fees were excluded from eligible deduction amount. Regarding interest expenses under Section 57, ITAT partially allowed the appeal, directing AO to recalculate disallowance based on closing loan balances rather than opening balances, while maintaining that interest on society loans constitutes capital expenditure.
ITAT ruled on three key issues in a capital gains case. The Tribunal determined Rs. 10,85,28,620 as full sale consideration for land rights relinquishment, rejecting assessee's claim for net amount adjustment against outstanding loans due to absence of explicit stipulation in resolutions. On Section 54F deduction, ITAT allowed relief following Karnataka HC precedent that investment of entire consideration within stipulated period suffices, even if construction remains incomplete. However, legal charges, advance maintenance, and certain registration fees were excluded from eligible deduction amount. Regarding interest expenses under Section 57, ITAT partially allowed the appeal, directing AO to recalculate disallowance based on closing loan balances rather than opening balances, while maintaining that interest on society loans constitutes capital expenditure.
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