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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HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
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