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 resolved two key issues for A.Y. 2017-18 involving a real estate developer's tax treatment of unsold flats. The tribunal held that notional rental income cannot be attributed to unsold flats held as stock-in-trade under section 22. The flats, being part of circulating capital and inventory intended for sale, do not satisfy the condition of "property not used for business purposes". Additionally, stamp duty, registration, and legal fees were deemed legitimate business expenses. The tribunal deleted the Assessing Officer's income addition and disallowance, ruling comprehensively in favor of the assessee based on the statutory provisions, asset nature, and judicial precedents.
ITAT resolved two key issues for A.Y. 2017-18 involving a real estate developer's tax treatment of unsold flats. The tribunal held that notional rental income cannot be attributed to unsold flats held as stock-in-trade under section 22. The flats, being part of circulating capital and inventory intended for sale, do not satisfy the condition of "property not used for business purposes". Additionally, stamp duty, registration, and legal fees were deemed legitimate business expenses. The tribunal deleted the Assessing Officer's income addition and disallowance, ruling comprehensively in favor of the assessee based on the statutory provisions, asset nature, and judicial precedents.
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