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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT addressed MAT computation under Section 115JB regarding interest subsidy received under TUF scheme. The Tribunal held that capital receipts and exempt income are to be excluded while computing book profits. Relying on previous decisions in similar cases involving Reliance Industries Limited and consistent judicial precedents, the Tribunal affirmed the CIT(A)'s order deleting the addition of interest subsidy while calculating book profit. The Tribunal distinguished earlier judgments related to Section 115J and emphasized the specific applicability to Section 115JB. Ultimately, the decision was rendered against the revenue, confirming that the interest subsidy should not be included in book profit calculations.
ITAT addressed MAT computation under Section 115JB regarding interest subsidy received under TUF scheme. The Tribunal held that capital receipts and exempt income are to be excluded while computing book profits. Relying on previous decisions in similar cases involving Reliance Industries Limited and consistent judicial precedents, the Tribunal affirmed the CIT(A)'s order deleting the addition of interest subsidy while calculating book profit. The Tribunal distinguished earlier judgments related to Section 115J and emphasized the specific applicability to Section 115JB. Ultimately, the decision was rendered against the revenue, confirming that the interest subsidy should not be included in book profit calculations.
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