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 allowed the assessee's appeal on multiple grounds. Regarding book profit computation under section 115JB, the Tribunal held that write-offs from court-approved capital reduction constitute transfer under section 2(47), following binding precedents from Gujarat HC and SC in Torrent and Apollo Tyres cases. The capital reduction was properly approved by Bombay HC and registered with ROC, resulting in share extinguishment and cancellation of investment rights. On procedural grounds, ITAT ruled CIT(A) improperly enhanced assessment by directing deemed dividend additions under sections 2(22)(d) and 115QA without issuing mandatory show-cause notice as required under section 251(2), relying on SC precedents in Chamaria and Mistry cases. For section 80IA deduction, ITAT allowed rental income from CFS operations as eligible business income, supported by CBDT circular and consistent treatment in previous assessment years for the same assessee.
ITAT allowed the assessee's appeal on multiple grounds. Regarding book profit computation under section 115JB, the Tribunal held that write-offs from court-approved capital reduction constitute transfer under section 2(47), following binding precedents from Gujarat HC and SC in Torrent and Apollo Tyres cases. The capital reduction was properly approved by Bombay HC and registered with ROC, resulting in share extinguishment and cancellation of investment rights. On procedural grounds, ITAT ruled CIT(A) improperly enhanced assessment by directing deemed dividend additions under sections 2(22)(d) and 115QA without issuing mandatory show-cause notice as required under section 251(2), relying on SC precedents in Chamaria and Mistry cases. For section 80IA deduction, ITAT allowed rental income from CFS operations as eligible business income, supported by CBDT circular and consistent treatment in previous assessment years for the same assessee.
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