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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT Decision Summary: The ITAT upheld the assessee's claims across multiple taxation issues. The tribunal rejected proportionate disallowance of interest expenditure under section 36(1)(iii), finding that advances to subsidiary companies promote business interests. Foreign travel expenditure was partially disallowed due to lack of business substantiation. Expenses for obtaining property approval were deemed allowable as directly related to share transfer value. The tribunal also rejected Minimum Alternate Tax (MAT) adjustments on goodwill impairment, noting the debits did not contravene statutory provisions. Regarding flat booking rates, the tribunal affirmed that variations in booking prices do not automatically indicate suppressed income, supporting the CIT(A)'s findings based on absence of corroborative evidence.
ITAT Decision Summary: The ITAT upheld the assessee's claims across multiple taxation issues. The tribunal rejected proportionate disallowance of interest expenditure under section 36(1)(iii), finding that advances to subsidiary companies promote business interests. Foreign travel expenditure was partially disallowed due to lack of business substantiation. Expenses for obtaining property approval were deemed allowable as directly related to share transfer value. The tribunal also rejected Minimum Alternate Tax (MAT) adjustments on goodwill impairment, noting the debits did not contravene statutory provisions. Regarding flat booking rates, the tribunal affirmed that variations in booking prices do not automatically indicate suppressed income, supporting the CIT(A)'s findings based on absence of corroborative evidence.
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