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 a dispute concerning foreign tax credit under Section 90, involving an ex-parte assessment order. The tribunal identified insufficient verification of the assessee's foreign tax credit claim. The appellate order mandates the assessee, based in Australia, to submit comprehensive documentation to the Assessing Officer (AO) within 90 days. The AO is directed to conduct a thorough verification, provide a hearing opportunity, and subsequently determine the legitimacy of the foreign tax credit and deduction claims. The entire appeal is remanded to the AO for detailed examination and potential reconsideration of the original assessment.
ITAT adjudicated a dispute concerning foreign tax credit under Section 90, involving an ex-parte assessment order. The tribunal identified insufficient verification of the assessee's foreign tax credit claim. The appellate order mandates the assessee, based in Australia, to submit comprehensive documentation to the Assessing Officer (AO) within 90 days. The AO is directed to conduct a thorough verification, provide a hearing opportunity, and subsequently determine the legitimacy of the foreign tax credit and deduction claims. The entire appeal is remanded to the AO for detailed examination and potential reconsideration of the original assessment.
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