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 multiple tax-related issues in favor of the assessee. The tribunal held that efficiency gain amounts must be set aside for regulatory consideration, with no independent discretion by the assessee. The decision affirmed the statutory obligation to allocate 50% of excess amounts generated from overreaching targets. Regarding electricity tax, energy duty, and consumer security deposit interest, the tribunal consistently ruled in the assessee's favor, allowing deductions and rejecting revenue's contentions. The tribunal also granted higher depreciation rates for UPS and computer accessories at 60% and confirmed deduction eligibility under Section 80IA, noting that additions to income do not impact the unit's deduction entitlement. Overall, the judgment substantially supported the assessee's tax treatment across multiple disputed aspects.
ITAT adjudicated multiple tax-related issues in favor of the assessee. The tribunal held that efficiency gain amounts must be set aside for regulatory consideration, with no independent discretion by the assessee. The decision affirmed the statutory obligation to allocate 50% of excess amounts generated from overreaching targets. Regarding electricity tax, energy duty, and consumer security deposit interest, the tribunal consistently ruled in the assessee's favor, allowing deductions and rejecting revenue's contentions. The tribunal also granted higher depreciation rates for UPS and computer accessories at 60% and confirmed deduction eligibility under Section 80IA, noting that additions to income do not impact the unit's deduction entitlement. Overall, the judgment substantially supported the assessee's tax treatment across multiple disputed aspects.
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