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 the revenue's appeal regarding classification of rental income under correct head of income. The assessee had treated rental income as business income rather than house property income while filing returns. The Coordinate Bench in assessee's own case for A.Y. 2011-12 previously held that assessee's rental income was assessable as "Income from Business." The Departmental Representative conceded that facts and circumstances for the current year were identical to A.Y. 2011-12, which was decided in assessee's favor. ITAT found no infirmity in CIT(A)'s order allowing the assessee to classify rental income as business income instead of house property income, upholding the lower authority's decision against the revenue.
ITAT dismissed the revenue's appeal regarding classification of rental income under correct head of income. The assessee had treated rental income as business income rather than house property income while filing returns. The Coordinate Bench in assessee's own case for A.Y. 2011-12 previously held that assessee's rental income was assessable as "Income from Business." The Departmental Representative conceded that facts and circumstances for the current year were identical to A.Y. 2011-12, which was decided in assessee's favor. ITAT found no infirmity in CIT(A)'s order allowing the assessee to classify rental income as business income instead of house property income, upholding the lower authority's decision against the revenue.
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