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 upheld the Assessing Officer's determination that the actual sale consideration for the immovable property was Rs. 5,04,80,000/-, rejecting the assessee's arrangement with True Value as a sham transaction designed to divert sale proceeds and reduce tax liability. True Value was neither the property owner nor the assessee's authorized agent, and the claimed 50% commission was unjustified. The Tribunal confirmed the reduction of the sale consideration from WDV of the block of assets and the consequent disallowance of excess depreciation of Rs. 25,48,000/-. However, the separate addition of Rs. 2.54 Crores for disallowance of expenditure was deleted as Revenue failed to establish that this amount was separately debited in the assessee's P&L account. The Revenue's appeal was partly allowed.
The ITAT upheld the Assessing Officer's determination that the actual sale consideration for the immovable property was Rs. 5,04,80,000/-, rejecting the assessee's arrangement with True Value as a sham transaction designed to divert sale proceeds and reduce tax liability. True Value was neither the property owner nor the assessee's authorized agent, and the claimed 50% commission was unjustified. The Tribunal confirmed the reduction of the sale consideration from WDV of the block of assets and the consequent disallowance of excess depreciation of Rs. 25,48,000/-. However, the separate addition of Rs. 2.54 Crores for disallowance of expenditure was deleted as Revenue failed to establish that this amount was separately debited in the assessee's P&L account. The Revenue's appeal was partly allowed.
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