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 ruled against Revenue in case involving double taxation of INR 6.90 crores differential amount received by Assessee from developer upon surrender of flat rights. Central Processing Unit erroneously added amount under Income from Other Sources head while processing return under section 143(1), despite Assessee having already included same amount in capital loss computation which was accepted. Form 26AS confirmed developer deducted tax at source on differential amount. CIT(A) correctly deleted the addition recognizing double taxation issue. ITAT upheld CIT(A)'s order, finding no infirmity in decision and confirming Revenue failed to appreciate correct facts regarding same income being taxed twice under different heads.
ITAT ruled against Revenue in case involving double taxation of INR 6.90 crores differential amount received by Assessee from developer upon surrender of flat rights. Central Processing Unit erroneously added amount under Income from Other Sources head while processing return under section 143(1), despite Assessee having already included same amount in capital loss computation which was accepted. Form 26AS confirmed developer deducted tax at source on differential amount. CIT(A) correctly deleted the addition recognizing double taxation issue. ITAT upheld CIT(A)'s order, finding no infirmity in decision and confirming Revenue failed to appreciate correct facts regarding same income being taxed twice under different heads.
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