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 ruled that denial of weighted deduction under s.35(2AB) does not prevent the assessee from claiming normal deduction for R&D expenditure under s.35(1)(i) and s.35(1)(iv). The Tribunal directed the AO to allow normal deduction for capital R&D expenditure under s.35(1)(iv) and delete the corresponding disallowance. Regarding s.80IC deduction for the Pantnagar plant, the ITAT held that profits reported in stand-alone audited financials were based on sound accounting principles, rejecting the AO's allegation of artificial profit creation. The Tribunal confirmed additional depreciation under s.32(1)(iia) for pollution control and energy-saving equipment as these qualified as "plant & machinery." Finally, following Sobha Developers Ltd., the ITAT held that s.14A disallowances cannot be added to book profit under s.115JB.
The ITAT ruled that denial of weighted deduction under s.35(2AB) does not prevent the assessee from claiming normal deduction for R&D expenditure under s.35(1)(i) and s.35(1)(iv). The Tribunal directed the AO to allow normal deduction for capital R&D expenditure under s.35(1)(iv) and delete the corresponding disallowance. Regarding s.80IC deduction for the Pantnagar plant, the ITAT held that profits reported in stand-alone audited financials were based on sound accounting principles, rejecting the AO's allegation of artificial profit creation. The Tribunal confirmed additional depreciation under s.32(1)(iia) for pollution control and energy-saving equipment as these qualified as "plant & machinery." Finally, following Sobha Developers Ltd., the ITAT held that s.14A disallowances cannot be added to book profit under s.115JB.
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