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 dismissed revenue's appeals for AY 2017-18 and 2018-19 regarding tax assessment on principal damages and interest additions. While assessee filed Form-1 under DTVSV for both years, the designated authority failed to process them within statutory timeline under Section 92(1). The disputed interest amounts were already declared and taxed in AY 2019-20, evidenced by Form-2. Since tax payment was completed in AY 2019-20 and Form-1 applications for earlier years lapsed due to non-processing within prescribed period, ITAT held revenue's appeals infructuous. The tribunal emphasized that revenue did not controvert assessee's evidence of tax payment or the expiry of Form-1 processing deadline.
ITAT dismissed revenue's appeals for AY 2017-18 and 2018-19 regarding tax assessment on principal damages and interest additions. While assessee filed Form-1 under DTVSV for both years, the designated authority failed to process them within statutory timeline under Section 92(1). The disputed interest amounts were already declared and taxed in AY 2019-20, evidenced by Form-2. Since tax payment was completed in AY 2019-20 and Form-1 applications for earlier years lapsed due to non-processing within prescribed period, ITAT held revenue's appeals infructuous. The tribunal emphasized that revenue did not controvert assessee's evidence of tax payment or the expiry of Form-1 processing deadline.
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