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 upheld the higher tax rate of 60% under section 115-BBE for assessment year 2017-18, reversing CIT(A)'s earlier determination. The tribunal followed precedential decisions from Kerala HC and coordinate bench rulings in Spectra Equipment and Chandan Garments cases. The amended provisions of section 115-BBE were deemed applicable, and the assessment order levying tax at 60% on income added under section 68 was consequently confirmed. The revenue's grounds were allowed, effectively establishing the retrospective applicability of the higher tax rate for the specified assessment year.
ITAT upheld the higher tax rate of 60% under section 115-BBE for assessment year 2017-18, reversing CIT(A)'s earlier determination. The tribunal followed precedential decisions from Kerala HC and coordinate bench rulings in Spectra Equipment and Chandan Garments cases. The amended provisions of section 115-BBE were deemed applicable, and the assessment order levying tax at 60% on income added under section 68 was consequently confirmed. The revenue's grounds were allowed, effectively establishing the retrospective applicability of the higher tax rate for the specified assessment year.
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