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 in favor of assessee regarding interest disallowance under Section 36(1)(iii). AO's contention of interest-free advances from interest-bearing funds was rejected as AO failed to establish diversion of funds for non-business purposes. Tribunal found substantial interest-free funds available with assessee from sister concerns, exceeding the disputed amount. Regarding stock valuation, ITAT upheld CIT(A)'s partial deletion of addition, maintaining Rs. 50,63,472 for consistency in FIFO method while deleting Rs. 3,95,62,067. On handling/spillage/wastage losses, ITAT accepted natural losses due to environmental factors and handling, noting no adverse findings during search proceedings or in previous assessments. AO's arbitrary disallowance was set aside as reasonable business losses were established.
ITAT ruled in favor of assessee regarding interest disallowance under Section 36(1)(iii). AO's contention of interest-free advances from interest-bearing funds was rejected as AO failed to establish diversion of funds for non-business purposes. Tribunal found substantial interest-free funds available with assessee from sister concerns, exceeding the disputed amount. Regarding stock valuation, ITAT upheld CIT(A)'s partial deletion of addition, maintaining Rs. 50,63,472 for consistency in FIFO method while deleting Rs. 3,95,62,067. On handling/spillage/wastage losses, ITAT accepted natural losses due to environmental factors and handling, noting no adverse findings during search proceedings or in previous assessments. AO's arbitrary disallowance was set aside as reasonable business losses were established.
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