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...
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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 speculative transaction losses, the tribunal held that commodity transactions were not conducted on NSEL platform and involved actual delivery with proper documentation, thus qualifying as business losses rather than speculative losses under Section 43(5). The AO's disallowance based solely on transactions with specific parties was deemed unacceptable. For futures and options losses, ITAT ruled these constituted legitimate hedging activities for the manufacturing business, not speculative transactions. Additional depreciation disallowance was reversed, following Godrej Industries Ltd precedent that balance depreciation benefit can be claimed in subsequent assessment years. Prior period income addition was allowed after verification of revised computation and tax payment. Purchase disallowances were deleted as NSEL confirmed peer-to-peer transactions with proper banking channel payments for cotton wash oil and mustard seeds.
ITAT allowed the assessee's appeal on multiple grounds. Regarding speculative transaction losses, the tribunal held that commodity transactions were not conducted on NSEL platform and involved actual delivery with proper documentation, thus qualifying as business losses rather than speculative losses under Section 43(5). The AO's disallowance based solely on transactions with specific parties was deemed unacceptable. For futures and options losses, ITAT ruled these constituted legitimate hedging activities for the manufacturing business, not speculative transactions. Additional depreciation disallowance was reversed, following Godrej Industries Ltd precedent that balance depreciation benefit can be claimed in subsequent assessment years. Prior period income addition was allowed after verification of revised computation and tax payment. Purchase disallowances were deleted as NSEL confirmed peer-to-peer transactions with proper banking channel payments for cotton wash oil and mustard seeds.
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