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...
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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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT partially allowed the assessee's appeal against revision under section 263. Regarding bonus payment of Rs. 2.02 crores, the Tribunal found that the AO had properly examined this issue during assessment proceedings, and the assessee had demonstrated payment before the return filing due date in compliance with section 43B. However, concerning interest expenses on PFC loans amounting to Rs. 17.91 crores, the Tribunal upheld the PCIT's finding that the AO erred in allowing unpaid interest without proper examination, violating section 43B requirements. On the third issue of Capital Grants & Subsidies and Consumer Contribution write-backs, the Tribunal rejected the PCIT's contention of shortfall, accepting the assessee's demonstration that the correct amounts were properly accounted for.
The ITAT partially allowed the assessee's appeal against revision under section 263. Regarding bonus payment of Rs. 2.02 crores, the Tribunal found that the AO had properly examined this issue during assessment proceedings, and the assessee had demonstrated payment before the return filing due date in compliance with section 43B. However, concerning interest expenses on PFC loans amounting to Rs. 17.91 crores, the Tribunal upheld the PCIT's finding that the AO erred in allowing unpaid interest without proper examination, violating section 43B requirements. On the third issue of Capital Grants & Subsidies and Consumer Contribution write-backs, the Tribunal rejected the PCIT's contention of shortfall, accepting the assessee's demonstration that the correct amounts were properly accounted for.
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