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 tax dispute concerning expense allocation and deduction claims under Section 80IC. The tribunal remanded the matter to the Assessing Officer for detailed expense bifurcation between multiple business units, mandating pro-rata allocation for common expenses like audit fees and directors' remuneration. Regarding export incentives and other income, the tribunal interpreted "derived" income narrowly, holding that only directly attributable income from the industrial undertaking qualifies for deduction. The tribunal ultimately upheld the lower authorities' decision, directing consideration of net interest for computing Section 80IC deductions, while providing specific guidelines for expense allocation across different business units.
ITAT adjudicated a tax dispute concerning expense allocation and deduction claims under Section 80IC. The tribunal remanded the matter to the Assessing Officer for detailed expense bifurcation between multiple business units, mandating pro-rata allocation for common expenses like audit fees and directors' remuneration. Regarding export incentives and other income, the tribunal interpreted "derived" income narrowly, holding that only directly attributable income from the industrial undertaking qualifies for deduction. The tribunal ultimately upheld the lower authorities' decision, directing consideration of net interest for computing Section 80IC deductions, while providing specific guidelines for expense allocation across different business units.
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