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 dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
ITAT dismissed revenue's appeal regarding TDS non-deduction on foreign payments under section 40(a)(i) and unexplained expenditure disallowance under section 69C. CIT(A)'s deletion of additions was upheld after assessee provided documentary evidence including Form 26AS showing TDS of Rs. 5,29,04,162/- deducted on payments to foreign entity. Regarding software expenses, ITAT confirmed CIT(A)'s finding that IT support charges constituted revenue expenditure rather than capital expenditure, as payments were for yearly renewable software licenses without acquiring proprietary rights. Revenue failed to controvert factual position with supporting evidence, resulting in dismissal of all grounds.
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