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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The ITAT deleted the disallowance made under s.14A read with Rule 8D(2)(ii) as the assessee demonstrated that investments were made in controlled entities requiring no expenditure to earn dividend income, and interest-free own funds exceeded investments. Following South Indian Bank Ltd., the Tribunal ruled in the assessee's favor. Additionally, the ITAT permitted the assessee's additional claim regarding export incentives under MEIS Scheme, holding that such rewards constitute capital receipts not chargeable to tax under normal provisions, relying on Eastman Exports Global. Further, following Ankit Metal and Power Limited, the Tribunal directed exclusion of MEIS amounts from book profit computation under s.115JB as they represent capital receipts.
The ITAT deleted the disallowance made under s.14A read with Rule 8D(2)(ii) as the assessee demonstrated that investments were made in controlled entities requiring no expenditure to earn dividend income, and interest-free own funds exceeded investments. Following South Indian Bank Ltd., the Tribunal ruled in the assessee's favor. Additionally, the ITAT permitted the assessee's additional claim regarding export incentives under MEIS Scheme, holding that such rewards constitute capital receipts not chargeable to tax under normal provisions, relying on Eastman Exports Global. Further, following Ankit Metal and Power Limited, the Tribunal directed exclusion of MEIS amounts from book profit computation under s.115JB as they represent capital receipts.
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