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 dispute involving MAT computation and interest levy. The tribunal held that the assessee's provision for doubtful debts, which was reduced from gross trade receivables and shown net in the balance sheet, constitutes a legitimate write-off not prohibited under Section 115JB. The tribunal found no legal basis for interest levy under Section 234A, as the return was filed before the statutory due date. Consequently, the tribunal allowed the assessee's appeal, eliminating the interest charge and validating the accounting treatment of doubtful debt provisions.
ITAT adjudicated a tax dispute involving MAT computation and interest levy. The tribunal held that the assessee's provision for doubtful debts, which was reduced from gross trade receivables and shown net in the balance sheet, constitutes a legitimate write-off not prohibited under Section 115JB. The tribunal found no legal basis for interest levy under Section 234A, as the return was filed before the statutory due date. Consequently, the tribunal allowed the assessee's appeal, eliminating the interest charge and validating the accounting treatment of doubtful debt provisions.
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