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 challenging CIT(A)'s allowance of deduction under Section 80IB. Assessing Officer denied deduction claiming residential units' carpet area exceeded prescribed 60 square meters limit under Section 80IBA without proper verification. AO relied solely on assessee's brochures and failed to refer matter to District Valuation Officer for measurement verification as required. Revenue provided no material evidence proving floor area exceeded statutory limit. CIT(A) properly verified records, sale deeds, and floor plans before allowing deduction. Local Authority's Building Use Certificate confirmed compliance with RERA Act Section 2(k) definition showing units under 60 square meters. ITAT upheld CIT(A)'s decision due to Revenue's failure to substantiate disallowance with proper evidence or DVO report.
ITAT dismissed Revenue's appeal challenging CIT(A)'s allowance of deduction under Section 80IB. Assessing Officer denied deduction claiming residential units' carpet area exceeded prescribed 60 square meters limit under Section 80IBA without proper verification. AO relied solely on assessee's brochures and failed to refer matter to District Valuation Officer for measurement verification as required. Revenue provided no material evidence proving floor area exceeded statutory limit. CIT(A) properly verified records, sale deeds, and floor plans before allowing deduction. Local Authority's Building Use Certificate confirmed compliance with RERA Act Section 2(k) definition showing units under 60 square meters. ITAT upheld CIT(A)'s decision due to Revenue's failure to substantiate disallowance with proper evidence or DVO report.
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