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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The ITAT quashed reassessment notices u/s 148 for AY 2014-15 and 2016-17 as time-barred, finding the notices were issued beyond the prescribed limitation period. The tribunal held that interest expenditure incurred for business purposes must be fully deducted in the year of expenditure, rejecting the AO's attempt to apportion interest between sales and work-in-progress. Applying the percentage of completion method and relying on ICDS IX provisions, the tribunal concluded that once development plans are obtained and units can be sold, interest capitalization ceases. The tribunal emphasized that when ICDS provisions conflict with the Income Tax Act, the Act's provisions prevail. Consequently, the revenue's appeal was dismissed, allowing the full interest expenditure deduction for the assessee.
The ITAT quashed reassessment notices u/s 148 for AY 2014-15 and 2016-17 as time-barred, finding the notices were issued beyond the prescribed limitation period. The tribunal held that interest expenditure incurred for business purposes must be fully deducted in the year of expenditure, rejecting the AO's attempt to apportion interest between sales and work-in-progress. Applying the percentage of completion method and relying on ICDS IX provisions, the tribunal concluded that once development plans are obtained and units can be sold, interest capitalization ceases. The tribunal emphasized that when ICDS provisions conflict with the Income Tax Act, the Act's provisions prevail. Consequently, the revenue's appeal was dismissed, allowing the full interest expenditure deduction for the assessee.
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