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 adjudicated a tax dispute regarding interest expense disallowance under Section 57(iii). The tribunal examined the assessee's loan transactions, noting borrowed funds exceeded loans advanced. Despite initially computing proportionate interest expense as disallowed, the tribunal ultimately ruled in the assessee's favor. The decision hinged on the direct investment of borrowed funds into a company and corresponding interest adjustment. Relying on precedent from a prior assessment year, the ITAT found the Assessing Officer's addition unsustainable, thereby granting relief to the assessee and confirming the proportionate interest expense treatment.
ITAT adjudicated a tax dispute regarding interest expense disallowance under Section 57(iii). The tribunal examined the assessee's loan transactions, noting borrowed funds exceeded loans advanced. Despite initially computing proportionate interest expense as disallowed, the tribunal ultimately ruled in the assessee's favor. The decision hinged on the direct investment of borrowed funds into a company and corresponding interest adjustment. Relying on precedent from a prior assessment year, the ITAT found the Assessing Officer's addition unsustainable, thereby granting relief to the assessee and confirming the proportionate interest expense treatment.
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