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 adjudicated a tax exemption dispute under section 10(23C)(iiiab), reversing the Assessing Officer's (AO) denial of exemption. The AO had initially rejected the exemption claim due to alleged non-compliance with return filing requirements. ITAT determined that no mandatory condition exists linking return filing under section 139(4C)(e) with exemption eligibility. The tribunal conclusively held the assessee eligible for the claimed tax exemption, allowing the assessee's appeal and deleting the contested addition, thereby providing a favorable judicial interpretation that prioritizes substantive compliance over procedural technicalities.
ITAT adjudicated a tax exemption dispute under section 10(23C)(iiiab), reversing the Assessing Officer's (AO) denial of exemption. The AO had initially rejected the exemption claim due to alleged non-compliance with return filing requirements. ITAT determined that no mandatory condition exists linking return filing under section 139(4C)(e) with exemption eligibility. The tribunal conclusively held the assessee eligible for the claimed tax exemption, allowing the assessee's appeal and deleting the contested addition, thereby providing a favorable judicial interpretation that prioritizes substantive compliance over procedural technicalities.
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