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 two key tax issues: (1) repairs and maintenance expenditure disallowance was restricted to 10% after reviewing submitted ledger accounts, upholding CIT(A)'s partial disallowance; (2) royalty expenses were deemed revenue expenditure under Section 37, rejecting Revenue's capital expenditure classification. The tribunal referenced precedential case law from Delhi HC, specifically EKL Appliances and Lumax Industries, which established year-to-year license/technical knowledge payments as revenue expenditure. Considering consistent treatment in prior assessment years and absence of ongoing benefit post-agreement termination, ITAT ruled comprehensively in assessee's favor, allowing full royalty expense deduction.
ITAT adjudicated two key tax issues: (1) repairs and maintenance expenditure disallowance was restricted to 10% after reviewing submitted ledger accounts, upholding CIT(A)'s partial disallowance; (2) royalty expenses were deemed revenue expenditure under Section 37, rejecting Revenue's capital expenditure classification. The tribunal referenced precedential case law from Delhi HC, specifically EKL Appliances and Lumax Industries, which established year-to-year license/technical knowledge payments as revenue expenditure. Considering consistent treatment in prior assessment years and absence of ongoing benefit post-agreement termination, ITAT ruled comprehensively in assessee's favor, allowing full royalty expense deduction.
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