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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HC held that the investment write-off claimed as a tax deduction was valid. The investment was made in furtherance of the company's memorandum of association objectives and was deemed unrecoverable. Unlike previous precedents involving capital compensation, this case involved a direct business investment. Given the identical factual and legal circumstances in a prior assessment year where the deduction was previously allowed, the court ruled in favor of the assessee, overturning the revenue department's disallowance and affirming the tax deduction's legitimacy.
HC held that the investment write-off claimed as a tax deduction was valid. The investment was made in furtherance of the company's memorandum of association objectives and was deemed unrecoverable. Unlike previous precedents involving capital compensation, this case involved a direct business investment. Given the identical factual and legal circumstances in a prior assessment year where the deduction was previously allowed, the court ruled in favor of the assessee, overturning the revenue department's disallowance and affirming the tax deduction's legitimacy.
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