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 adjudicated multiple issues involving tax assessment for the assessee. Key determinations included: (1) upholding addition under Section 69C for undisclosed project expenditure based on matching accounting figures, (2) disallowing depreciation on gym equipment not installed at business premises, (3) accepting cancellation of property sale agreement and refund of advance, (4) allowing rent expenses for business premises despite procedural oversight, (5) validating foreign travel expenses for legitimate business purpose of marble procurement, and (6) deleting deemed profit additions and advance receipt additions due to lack of substantive evidence. Overall, most grounds were decided either partially or fully in favor of the assessee, with the tribunal emphasizing substantive compliance over procedural technicalities.
The ITAT adjudicated multiple issues involving tax assessment for the assessee. Key determinations included: (1) upholding addition under Section 69C for undisclosed project expenditure based on matching accounting figures, (2) disallowing depreciation on gym equipment not installed at business premises, (3) accepting cancellation of property sale agreement and refund of advance, (4) allowing rent expenses for business premises despite procedural oversight, (5) validating foreign travel expenses for legitimate business purpose of marble procurement, and (6) deleting deemed profit additions and advance receipt additions due to lack of substantive evidence. Overall, most grounds were decided either partially or fully in favor of the assessee, with the tribunal emphasizing substantive compliance over procedural technicalities.
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