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 appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
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