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 ruled on multiple tax-related issues involving property income and expense claims. The tribunal upheld CIT(A)'s deletion of additions related to rent reimbursement and unrealized debtors, finding no procedural irregularities. Regarding construction expenses under section 40(a)(ia), the tribunal directed the Assessing Officer to re-examine the TDS compliance and verify the assessee's claims about material provision and service portion taxation. The decision emphasized consistency in income recognition and adherence to statutory provisions, remanding the construction expenses issue for fresh assessment in alignment with the assessee's revenue recognition method.
ITAT ruled on multiple tax-related issues involving property income and expense claims. The tribunal upheld CIT(A)'s deletion of additions related to rent reimbursement and unrealized debtors, finding no procedural irregularities. Regarding construction expenses under section 40(a)(ia), the tribunal directed the Assessing Officer to re-examine the TDS compliance and verify the assessee's claims about material provision and service portion taxation. The decision emphasized consistency in income recognition and adherence to statutory provisions, remanding the construction expenses issue for fresh assessment in alignment with the assessee's revenue recognition method.
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