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 the assessee's appeal regarding NSEL trading losses, reversing CIT(A)'s disallowance. The tribunal held that transactions entered for fund availability constituted legitimate business activity, with resulting losses representing cost of funds rather than non-genuine trades. Loss withdrawal explanations were deemed satisfactory, establishing business purpose. Regarding castor seeds purchases, ITAT upheld CIT(A)'s deletion of additions, finding adequate documentation through stock registers, purchase details, and payment proofs via HDFC Settlement Account. The assessee demonstrated actual receipt of goods at specified locations, proper accounting integration, and legitimate business operations including crushing and sales activities, with no doubts raised regarding quantities or manufacturing processes.
ITAT allowed the assessee's appeal regarding NSEL trading losses, reversing CIT(A)'s disallowance. The tribunal held that transactions entered for fund availability constituted legitimate business activity, with resulting losses representing cost of funds rather than non-genuine trades. Loss withdrawal explanations were deemed satisfactory, establishing business purpose. Regarding castor seeds purchases, ITAT upheld CIT(A)'s deletion of additions, finding adequate documentation through stock registers, purchase details, and payment proofs via HDFC Settlement Account. The assessee demonstrated actual receipt of goods at specified locations, proper accounting integration, and legitimate business operations including crushing and sales activities, with no doubts raised regarding quantities or manufacturing processes.
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