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 exemption u/s 10(2A) to assessee LLP for share of profit received from partnership firm. CIT(A) had denied exemption contending LLP cannot become partner in partnership firm. ITAT held that assessee LLP was duly registered as partner by Registrar of Firms in partnership deed of M/s. Kothari Autolines. Partnership firm had offered income to tax and distributed profits to partners after paying due tax. ITAT found no justification for denying exemption when income already suffered tax at partnership level and only post-tax profits were distributed. CIT(A)'s findings set aside and exemption claim allowed. Appeal succeeded.
ITAT allowed exemption u/s 10(2A) to assessee LLP for share of profit received from partnership firm. CIT(A) had denied exemption contending LLP cannot become partner in partnership firm. ITAT held that assessee LLP was duly registered as partner by Registrar of Firms in partnership deed of M/s. Kothari Autolines. Partnership firm had offered income to tax and distributed profits to partners after paying due tax. ITAT found no justification for denying exemption when income already suffered tax at partnership level and only post-tax profits were distributed. CIT(A)'s findings set aside and exemption claim allowed. Appeal succeeded.
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