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 CIT(A)'s decision favoring the assessee on multiple disputed deductions. The City Environment Expenses were allowed as sunk costs incurred for development of notified area, not generating future revenue. Contribution & Aid Expenses to other institutions were permitted as business expenditure following precedent that such expenditure indirectly benefits business operations. IMC Transfer Expenses were allowed considering assessee's status as state government wing, established audit procedures, and consistency with prior years' treatment. Land acquisition and diversion expenses were validated as revenue-neutral since they formed part of Work-in-Progress/stock, effectively resulting in no deduction claim. ITAT emphasized the principle of consistency in tax authorities' approach absent changes in facts or law, maintaining prior assessment treatments under Section 143(3).
ITAT upheld CIT(A)'s decision favoring the assessee on multiple disputed deductions. The City Environment Expenses were allowed as sunk costs incurred for development of notified area, not generating future revenue. Contribution & Aid Expenses to other institutions were permitted as business expenditure following precedent that such expenditure indirectly benefits business operations. IMC Transfer Expenses were allowed considering assessee's status as state government wing, established audit procedures, and consistency with prior years' treatment. Land acquisition and diversion expenses were validated as revenue-neutral since they formed part of Work-in-Progress/stock, effectively resulting in no deduction claim. ITAT emphasized the principle of consistency in tax authorities' approach absent changes in facts or law, maintaining prior assessment treatments under Section 143(3).
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