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 allowed the assessee's appeal regarding transfer pricing adjustments for power supply, ruling that the assessee's method for determining arm's length price was correct and the AO's adjustments were inconsistent with Income Tax Act provisions. Similarly, on steam transfer pricing, the Tribunal rejected the AO's Cost-Plus Method approach, finding it inconsistent with case facts and noting the AO erroneously reduced losses already considered by the assessee. The Tribunal disallowed the assessee's claim for deduction under section 80G for CSR contributions, holding that allowing such deductions would defeat the fundamental purpose of CSR expenditure. However, regarding deemed income under section 41(1), the ITAT allowed the appeal, finding that disallowance would constitute double taxation as the assessee had already deducted the amount in the subsequent year's return.
The ITAT allowed the assessee's appeal regarding transfer pricing adjustments for power supply, ruling that the assessee's method for determining arm's length price was correct and the AO's adjustments were inconsistent with Income Tax Act provisions. Similarly, on steam transfer pricing, the Tribunal rejected the AO's Cost-Plus Method approach, finding it inconsistent with case facts and noting the AO erroneously reduced losses already considered by the assessee. The Tribunal disallowed the assessee's claim for deduction under section 80G for CSR contributions, holding that allowing such deductions would defeat the fundamental purpose of CSR expenditure. However, regarding deemed income under section 41(1), the ITAT allowed the appeal, finding that disallowance would constitute double taxation as the assessee had already deducted the amount in the subsequent year's return.
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