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 taxation issues, allowing partial relief to the assessee. The tribunal primarily focused on procedural and jurisdictional challenges, remanding certain matters back to the Assessing Officer (AO) for fresh verification. Key holdings included: (1) CIT(A) lacked jurisdiction to enhance income through new sources under section 251(2), (2) advances written off to be re-examined by AO with fresh evidence, (3) no disallowance under section 14A due to absence of exempt income, and (4) PF and ESI contribution delays to be reassessed based on salary disbursement dates. The tribunal's approach emphasized procedural fairness and detailed factual re-examination rather than conclusive substantive determinations.
ITAT adjudicated multiple taxation issues, allowing partial relief to the assessee. The tribunal primarily focused on procedural and jurisdictional challenges, remanding certain matters back to the Assessing Officer (AO) for fresh verification. Key holdings included: (1) CIT(A) lacked jurisdiction to enhance income through new sources under section 251(2), (2) advances written off to be re-examined by AO with fresh evidence, (3) no disallowance under section 14A due to absence of exempt income, and (4) PF and ESI contribution delays to be reassessed based on salary disbursement dates. The tribunal's approach emphasized procedural fairness and detailed factual re-examination rather than conclusive substantive determinations.
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