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 allowed multiple grounds of appeal, deleting disallowances across several taxation issues. The tribunal found in favor of the assessee regarding unclaimed balances written off, prior period expenses, and advances received on land sale. Specifically, the ITAT deleted additions under Section 2(22)(e) relating to deemed dividend, rejected capital nature claims for repair expenses, and removed proportionate interest expenditure disallowance. The tribunal emphasized that expenses were business-related, repairs were necessary for operational purposes, and borrowed funds could be presumed to have been utilized from owned funds when sufficient internal resources existed. The decision comprehensively reinstated the assessee's claimed deductions and income treatments across multiple disputed taxation aspects.
ITAT allowed multiple grounds of appeal, deleting disallowances across several taxation issues. The tribunal found in favor of the assessee regarding unclaimed balances written off, prior period expenses, and advances received on land sale. Specifically, the ITAT deleted additions under Section 2(22)(e) relating to deemed dividend, rejected capital nature claims for repair expenses, and removed proportionate interest expenditure disallowance. The tribunal emphasized that expenses were business-related, repairs were necessary for operational purposes, and borrowed funds could be presumed to have been utilized from owned funds when sufficient internal resources existed. The decision comprehensively reinstated the assessee's claimed deductions and income treatments across multiple disputed taxation aspects.
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