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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ITAT upheld the CIT(A)'s deletion of two additions made by the AO. First, interest earned from deposits was correctly held to be inextricably linked with setting up the plant, following Bokaro Steels Limited (1998), and thus not taxable as "Income from other sources." Second, the Tribunal confirmed deletion of share premium disallowance under s. 56(2)(viib), as the shares were issued to an existing shareholder whose identity and creditworthiness were established. The valuation of Rs. 12 per share was properly determined using the DCF method prescribed by RBI, and the AO had not disputed this valuation methodology. Appeal decided against Revenue.
ITAT upheld the CIT(A)'s deletion of two additions made by the AO. First, interest earned from deposits was correctly held to be inextricably linked with setting up the plant, following Bokaro Steels Limited (1998), and thus not taxable as "Income from other sources." Second, the Tribunal confirmed deletion of share premium disallowance under s. 56(2)(viib), as the shares were issued to an existing shareholder whose identity and creditworthiness were established. The valuation of Rs. 12 per share was properly determined using the DCF method prescribed by RBI, and the AO had not disputed this valuation methodology. Appeal decided against Revenue.
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