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 allowed the Department's appeal regarding late deposit of employees' PF contributions, following the Supreme Court's Checkmate Services precedent. The Tribunal dismissed Revenue's grounds concerning disallowance of interest on unneeded loans, finding the investment in Ethiopotash B.V. was directly linked to the assessee's business to control raw material supply. ITAT upheld CIT(A)'s findings against rejection of books under s.145(3), determining the AO failed to properly verify submitted information before estimation. The Tribunal allowed full-year depreciation despite partial plant operation, following precedent on the wear and tear concept. ITAT also dismissed Revenue's appeals regarding additions under s.68 for alleged bogus share applications and unsecured loans, as the assessee adequately established identity, creditworthiness, and transaction genuineness.
ITAT allowed the Department's appeal regarding late deposit of employees' PF contributions, following the Supreme Court's Checkmate Services precedent. The Tribunal dismissed Revenue's grounds concerning disallowance of interest on unneeded loans, finding the investment in Ethiopotash B.V. was directly linked to the assessee's business to control raw material supply. ITAT upheld CIT(A)'s findings against rejection of books under s.145(3), determining the AO failed to properly verify submitted information before estimation. The Tribunal allowed full-year depreciation despite partial plant operation, following precedent on the wear and tear concept. ITAT also dismissed Revenue's appeals regarding additions under s.68 for alleged bogus share applications and unsecured loans, as the assessee adequately established identity, creditworthiness, and transaction genuineness.
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