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 partial relief to the Assessee, directing recalculation of tax liability. The tribunal rejected Revenue's contentions regarding Section 80IA deduction, affirming that deduction must be calculated from Gross Total Income. The ITAT mandated the Assessing Officer to verify and allow Section 80IA deduction, permit credit for Dividend Distribution Tax after challan verification, and recompute interest/demand accordingly. The tribunal also upheld previous judicial precedents regarding Section 14A amendments, rejecting Revenue's retrospective application argument. The order fundamentally upholds the Assessee's claims while providing procedural guidance for tax computation.
ITAT allowed partial relief to the Assessee, directing recalculation of tax liability. The tribunal rejected Revenue's contentions regarding Section 80IA deduction, affirming that deduction must be calculated from Gross Total Income. The ITAT mandated the Assessing Officer to verify and allow Section 80IA deduction, permit credit for Dividend Distribution Tax after challan verification, and recompute interest/demand accordingly. The tribunal also upheld previous judicial precedents regarding Section 14A amendments, rejecting Revenue's retrospective application argument. The order fundamentally upholds the Assessee's claims while providing procedural guidance for tax computation.
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