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 client assistant charges paid to ICICI Bank Ltd constitute legitimate business expenditure. The court rejected revenue's disallowance of expenses, finding that: (1) sharing brokerage with ICICI Bank does not invalidate the expenditure, (2) the bank's deposit earnings cannot negate the assessee's legitimate business expense, and (3) the expenses were directly connected to the broking business infrastructure. Regarding notional losses, the court followed SC precedent in Suzlon Energy Ltd, allowing deductions based on conservative accounting principles. No substantial questions of law were identified, and both revenue's and assessee's proposed questions were consequently dismissed.
HC held that client assistant charges paid to ICICI Bank Ltd constitute legitimate business expenditure. The court rejected revenue's disallowance of expenses, finding that: (1) sharing brokerage with ICICI Bank does not invalidate the expenditure, (2) the bank's deposit earnings cannot negate the assessee's legitimate business expense, and (3) the expenses were directly connected to the broking business infrastructure. Regarding notional losses, the court followed SC precedent in Suzlon Energy Ltd, allowing deductions based on conservative accounting principles. No substantial questions of law were identified, and both revenue's and assessee's proposed questions were consequently dismissed.
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