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 dismissed the assessee's appeal, rejecting the claim for full expenditure deduction related to exhibition expenses. The tribunal determined that while brand promotion was involved, the entire expenditure cannot be claimed due to the separate entity principle. The court reasonably allowed 25% of expenses, which was more favorable than the assessee's 10% profit share, emphasizing the subjective nature of determining indirect benefits based on specific case facts and commercial context.
ITAT dismissed the assessee's appeal, rejecting the claim for full expenditure deduction related to exhibition expenses. The tribunal determined that while brand promotion was involved, the entire expenditure cannot be claimed due to the separate entity principle. The court reasonably allowed 25% of expenses, which was more favorable than the assessee's 10% profit share, emphasizing the subjective nature of determining indirect benefits based on specific case facts and commercial context.
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