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 allowed the appeal regarding depreciation on goodwill post-demerger for AYs 2015-16 and 2016-17. The court determined that the 5th proviso to Sec 32 only applies in the year of succession regarding aggregate deduction by predecessor and successor, not subsequent years. The Tribunal erroneously based its judgment solely on the Fifth Proviso's applicability, which was irrelevant for the assessment years in question. The scheme became effective in FY 2013-14, making the proviso applicable only for AY 2014-15. Matter remitted to Tribunal for fresh examination, considering the proviso's temporal scope and aggregate deduction requirement. Original Tribunal order dated 03 February 2023 set aside.
HC allowed the appeal regarding depreciation on goodwill post-demerger for AYs 2015-16 and 2016-17. The court determined that the 5th proviso to Sec 32 only applies in the year of succession regarding aggregate deduction by predecessor and successor, not subsequent years. The Tribunal erroneously based its judgment solely on the Fifth Proviso's applicability, which was irrelevant for the assessment years in question. The scheme became effective in FY 2013-14, making the proviso applicable only for AY 2014-15. Matter remitted to Tribunal for fresh examination, considering the proviso's temporal scope and aggregate deduction requirement. Original Tribunal order dated 03 February 2023 set aside.
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