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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SC referred a split decision regarding deductions under Sections 80HHC and 80IA to a three-judge bench. The court interpreted Section 80IA(9) as restricting the aggregate deductions under heading C of Chapter VI-A to 100% of business profits, without affecting the computation of individual deductions. The provision aims to prevent taxpayers from claiming repeated deductions on the same eligible income. The court endorsed the Bombay HC's interpretation that the restriction applies to deduction allowability rather than gross income computation, ensuring that total deductions do not exceed the eligible business profits.
SC referred a split decision regarding deductions under Sections 80HHC and 80IA to a three-judge bench. The court interpreted Section 80IA(9) as restricting the aggregate deductions under heading C of Chapter VI-A to 100% of business profits, without affecting the computation of individual deductions. The provision aims to prevent taxpayers from claiming repeated deductions on the same eligible income. The court endorsed the Bombay HC's interpretation that the restriction applies to deduction allowability rather than gross income computation, ensuring that total deductions do not exceed the eligible business profits.
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