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 dismissed the Revenue's appeal against disallowance of interest expenses. The Tribunal held that the assessee's investment in compulsory convertible debentures of Shreeniwas Cotton Mills Ltd., which increased its shareholding from 95.30% to 99.76%, was made to acquire controlling interest in its subsidiary and therefore constituted a business purpose. The assessee demonstrated that it had interest-free investment of Rs. 505.32 crores, presumed to be funded from non-interest bearing funds of OCD worth Rs. 450 crores. The ITAT affirmed the CIT(A)'s finding that investments made to acquire controlling interest in another company are considered to be for business purposes.
The ITAT dismissed the Revenue's appeal against disallowance of interest expenses. The Tribunal held that the assessee's investment in compulsory convertible debentures of Shreeniwas Cotton Mills Ltd., which increased its shareholding from 95.30% to 99.76%, was made to acquire controlling interest in its subsidiary and therefore constituted a business purpose. The assessee demonstrated that it had interest-free investment of Rs. 505.32 crores, presumed to be funded from non-interest bearing funds of OCD worth Rs. 450 crores. The ITAT affirmed the CIT(A)'s finding that investments made to acquire controlling interest in another company are considered to be for business purposes.
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