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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HC allowed assessee's appeal challenging the Assessing Officer's disallowance of mutual fund promotion and initial public offer expenditure. The court held that the AO cannot substitute his discretion for the assessee's business judgment regarding expense reasonableness. The expenditure was deemed to be incurred for commercial expediency, with a direct nexus to the assessee's business activities. The court emphasized that expenses related to group company operations and business expansion should be considered legitimate business expenditure. Consequently, the expenses were deemed allowable and eligible for deduction in the assessee's income tax return, thereby providing a favorable ruling for the taxpayer's claim.
HC allowed assessee's appeal challenging the Assessing Officer's disallowance of mutual fund promotion and initial public offer expenditure. The court held that the AO cannot substitute his discretion for the assessee's business judgment regarding expense reasonableness. The expenditure was deemed to be incurred for commercial expediency, with a direct nexus to the assessee's business activities. The court emphasized that expenses related to group company operations and business expansion should be considered legitimate business expenditure. Consequently, the expenses were deemed allowable and eligible for deduction in the assessee's income tax return, thereby providing a favorable ruling for the taxpayer's claim.
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