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 reversed ITAT's ruling on allowance of bad debts under Section 36(1)(vii) of the Act. The court found that Assessee's claim failed to meet statutory requirements as the debt was neither accounted for in computing prior year income nor represented money lent in ordinary course of banking/lending business. HC determined the arrangement between Assessee and CIPL (group company) was a deliberate device to transfer losses from loss-making entity to profit-making entity within same group. Evidence showed CIPL had financial capacity to partially settle dues, demonstrated by its Rs. 10 crore donation. The court concluded this was a colorable device to reduce tax liability, with CIPL benefiting from liability write-off while being tax-exempt due to losses.
HC reversed ITAT's ruling on allowance of bad debts under Section 36(1)(vii) of the Act. The court found that Assessee's claim failed to meet statutory requirements as the debt was neither accounted for in computing prior year income nor represented money lent in ordinary course of banking/lending business. HC determined the arrangement between Assessee and CIPL (group company) was a deliberate device to transfer losses from loss-making entity to profit-making entity within same group. Evidence showed CIPL had financial capacity to partially settle dues, demonstrated by its Rs. 10 crore donation. The court concluded this was a colorable device to reduce tax liability, with CIPL benefiting from liability write-off while being tax-exempt due to losses.
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