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 upheld CIT(A)'s order, dismissing revenue's appeal regarding brokerage expenses. The tribunal found that brokerage expenses were legitimate business expenditures paid through banking channels, supported by invoices. The expenses were incurred as selling costs, consistent with IND AS-2, and could not be capitalized. The assessee's books were properly maintained and audited, demonstrating substantial income from business activities. The appellate tribunal concluded that the brokerage payments were normal selling expenses for a large-scale construction business, and therefore, the addition made by the Assessing Officer was unwarranted.
ITAT upheld CIT(A)'s order, dismissing revenue's appeal regarding brokerage expenses. The tribunal found that brokerage expenses were legitimate business expenditures paid through banking channels, supported by invoices. The expenses were incurred as selling costs, consistent with IND AS-2, and could not be capitalized. The assessee's books were properly maintained and audited, demonstrating substantial income from business activities. The appellate tribunal concluded that the brokerage payments were normal selling expenses for a large-scale construction business, and therefore, the addition made by the Assessing Officer was unwarranted.
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