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 reversed the CIT(A)/NFAC's disallowance of interest expenses claimed under section 57(iii). The Tribunal held that the appellant had successfully established the requisite nexus between borrowed funds on which interest was paid and the funds lent on which interest was earned, satisfying the statutory requirements. The ITAT noted that the Assessing Officer had allowed similar deduction claims in subsequent assessment years after scrutiny of the same loans and advances. Consequently, the Tribunal set aside the CIT(A)/NFAC's order and ruled in favor of the appellant, allowing the deduction of interest expenditure under section 57.
The ITAT reversed the CIT(A)/NFAC's disallowance of interest expenses claimed under section 57(iii). The Tribunal held that the appellant had successfully established the requisite nexus between borrowed funds on which interest was paid and the funds lent on which interest was earned, satisfying the statutory requirements. The ITAT noted that the Assessing Officer had allowed similar deduction claims in subsequent assessment years after scrutiny of the same loans and advances. Consequently, the Tribunal set aside the CIT(A)/NFAC's order and ruled in favor of the appellant, allowing the deduction of interest expenditure under section 57.
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