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 Decision Summary: The ITAT predominantly ruled against the assessee, dismissing most appeal grounds related to foreign exchange forward contracts, treating the transaction as a revenue receipt rather than capital in nature. The tribunal directed restoration of certain issues to CIT(A) for de novo adjudication, specifically regarding finance costs, notional gains on derecognition of financial liabilities, and closing stock matters. The tribunal confirmed the lower authorities' order on liquidated damages and section 14A provisions. Key findings emphasized the importance of full factual disclosure and compliance with statutory notices, with a clear warning that non-compliance could result in adverse interpretations against the assessee.
ITAT Decision Summary: The ITAT predominantly ruled against the assessee, dismissing most appeal grounds related to foreign exchange forward contracts, treating the transaction as a revenue receipt rather than capital in nature. The tribunal directed restoration of certain issues to CIT(A) for de novo adjudication, specifically regarding finance costs, notional gains on derecognition of financial liabilities, and closing stock matters. The tribunal confirmed the lower authorities' order on liquidated damages and section 14A provisions. Key findings emphasized the importance of full factual disclosure and compliance with statutory notices, with a clear warning that non-compliance could result in adverse interpretations against the assessee.
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