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 resolved multiple taxation issues in favor of the assessee. The tribunal upheld deductions under section 36(1)(iii), rejected revenue's appeals regarding section 14A expenses, and allowed reclassification of income. Regarding Ind-AS accounting method transition, the tribunal found the claim bona fide and revenue-neutral, permitting adjustment with safeguards against double taxation. The tribunal dismissed revenue's appeals on TDS under section 194C for statutory authority payments and remanded unverified purchase transactions for fresh consideration, granting the assessee an opportunity to substantiate transaction genuineness before the Assessing Officer.
ITAT resolved multiple taxation issues in favor of the assessee. The tribunal upheld deductions under section 36(1)(iii), rejected revenue's appeals regarding section 14A expenses, and allowed reclassification of income. Regarding Ind-AS accounting method transition, the tribunal found the claim bona fide and revenue-neutral, permitting adjustment with safeguards against double taxation. The tribunal dismissed revenue's appeals on TDS under section 194C for statutory authority payments and remanded unverified purchase transactions for fresh consideration, granting the assessee an opportunity to substantiate transaction genuineness before the Assessing Officer.
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