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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HC determined that interest income from staff loans and other loans, earned by an electricity distribution entity, constitutes business income. Drawing from precedent in Gujarat Urja Vikas Nigam Limited and Gujarat Energy Transmission Corporation Ltd., the court held that such interest is directly related to the assessee's core business operations. Consequently, no substantial question of law exists, and the interest should be categorized as business income rather than income from other sources. The assessee's appeal was ultimately allowed, affirming the treatment of loan interest as an integral component of business revenue.
HC determined that interest income from staff loans and other loans, earned by an electricity distribution entity, constitutes business income. Drawing from precedent in Gujarat Urja Vikas Nigam Limited and Gujarat Energy Transmission Corporation Ltd., the court held that such interest is directly related to the assessee's core business operations. Consequently, no substantial question of law exists, and the interest should be categorized as business income rather than income from other sources. The assessee's appeal was ultimately allowed, affirming the treatment of loan interest as an integral component of business revenue.
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