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 exemption dispute involving an educational trust's income. The tribunal set aside prior assessment orders due to unaudited financial statements. The case was remanded to the Assessing Officer (AO) for de novo assessment, mandating a comprehensive review of the trust's financial documentation. The AO must provide the assessee an opportunity to present evidence regarding expenditure incurred for income generation. The tribunal directed that only the excess income over expenditure should be subjected to taxation, consistent with previous assessment years. The appeal was allowed for statistical purposes, effectively requiring a procedurally corrected reassessment of the trust's tax liability under section 10(23C)(iiiad).
ITAT adjudicated a tax exemption dispute involving an educational trust's income. The tribunal set aside prior assessment orders due to unaudited financial statements. The case was remanded to the Assessing Officer (AO) for de novo assessment, mandating a comprehensive review of the trust's financial documentation. The AO must provide the assessee an opportunity to present evidence regarding expenditure incurred for income generation. The tribunal directed that only the excess income over expenditure should be subjected to taxation, consistent with previous assessment years. The appeal was allowed for statistical purposes, effectively requiring a procedurally corrected reassessment of the trust's tax liability under section 10(23C)(iiiad).
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