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 the assessee's appeal regarding capital gains deduction. Despite initially claiming deduction under an incorrect section (54), the tribunal held that procedural errors do not preclude legitimate tax benefits if substantive eligibility criteria are met. The tribunal remitted the matter to the Assessing Officer with directions to evaluate the deduction claim under section 54F based on evidence submitted. The assessee was granted an opportunity to furnish additional documentation and present arguments. The appellate order effectively reinstated the potential tax exemption by focusing on the substantive legal entitlement rather than technical procedural defects.
ITAT allowed the assessee's appeal regarding capital gains deduction. Despite initially claiming deduction under an incorrect section (54), the tribunal held that procedural errors do not preclude legitimate tax benefits if substantive eligibility criteria are met. The tribunal remitted the matter to the Assessing Officer with directions to evaluate the deduction claim under section 54F based on evidence submitted. The assessee was granted an opportunity to furnish additional documentation and present arguments. The appellate order effectively reinstated the potential tax exemption by focusing on the substantive legal entitlement rather than technical procedural defects.
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