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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The ITAT resolved a taxation dispute concerning option money and capital gains from a joint venture stake sale. The Tribunal directed the AO to compute capital gains based on prior judicial precedents, which established the option money as a capital receipt. The decision affirmed the assessee's position that the 940 crore receipt should be treated as capital gains rather than business income. The Tribunal further instructed the AO to allow deductions for capitalized interest and professional expenses related to share acquisition, subject to verification. The ruling predominantly favored the assessee by mandating capital gains treatment and rejecting the revenue department's business income classification.
The ITAT resolved a taxation dispute concerning option money and capital gains from a joint venture stake sale. The Tribunal directed the AO to compute capital gains based on prior judicial precedents, which established the option money as a capital receipt. The decision affirmed the assessee's position that the 940 crore receipt should be treated as capital gains rather than business income. The Tribunal further instructed the AO to allow deductions for capitalized interest and professional expenses related to share acquisition, subject to verification. The ruling predominantly favored the assessee by mandating capital gains treatment and rejecting the revenue department's business income classification.
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