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 held that pre-operating expenses claimed by assessee as revenue expenditure were correctly disallowed. Tribunal established that mere nomenclature in books cannot determine expense allowability, applying precedents from India Discount Co. Ltd., Provincial Farmers Ltd., and KCP Ltd. Evidence demonstrated payments related to business expansion into new geographical areas before commercial exploitation, constituting capital expenditure. Regarding customer acquisition costs, ITAT sustained CIT(A)'s decision allowing 50% expenditure, recognizing revenue nature while applying amortization principle. Tribunal rejected assessee's argument for full deduction in current assessment year, upholding partial allowance approach for expenses benefiting future years despite assessee's non-election of amortization treatment.
ITAT held that pre-operating expenses claimed by assessee as revenue expenditure were correctly disallowed. Tribunal established that mere nomenclature in books cannot determine expense allowability, applying precedents from India Discount Co. Ltd., Provincial Farmers Ltd., and KCP Ltd. Evidence demonstrated payments related to business expansion into new geographical areas before commercial exploitation, constituting capital expenditure. Regarding customer acquisition costs, ITAT sustained CIT(A)'s decision allowing 50% expenditure, recognizing revenue nature while applying amortization principle. Tribunal rejected assessee's argument for full deduction in current assessment year, upholding partial allowance approach for expenses benefiting future years despite assessee's non-election of amortization treatment.
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