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 complex tax dispute involving a life insurance entity's income classification. The tribunal consistently upheld the assessee's position that shareholders' and policyholders' accounts, maintained separately for legal compliance, should be treated as part of a single insurance business. The ruling affirmed the computation of income from shareholders' account under "Profits and Gains of Business or Profession" and granted exemptions under sections 10(34), 10(23AAB), and 10(15). The revenue's appeal was dismissed, with the tribunal finding no procedural or substantive infirmities in the lower appellate authority's findings, thereby maintaining the tax treatment favorable to the assessee.
ITAT adjudicated a complex tax dispute involving a life insurance entity's income classification. The tribunal consistently upheld the assessee's position that shareholders' and policyholders' accounts, maintained separately for legal compliance, should be treated as part of a single insurance business. The ruling affirmed the computation of income from shareholders' account under "Profits and Gains of Business or Profession" and granted exemptions under sections 10(34), 10(23AAB), and 10(15). The revenue's appeal was dismissed, with the tribunal finding no procedural or substantive infirmities in the lower appellate authority's findings, thereby maintaining the tax treatment favorable to the assessee.
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