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 disallowance of interest expenditure. The AO had disallowed interest claiming funds were diverted for non-business purposes. The assessee, engaged in manufacturing, trading and export of woolen carpets, maintained that interest expenditure in P&L account was exclusively for business purposes related to bank credit limits. Upon examining the ledger accounts, ITAT found that claimed interest expenditure was properly reflected in business accounts and was distinct from personal home loan interest paid to ICICI Bank Ltd. The tribunal concluded that the interest expenditure was legitimately incurred for business purposes, deleted the disallowance, and allowed the appeal in favor of the assessee.
ITAT allowed the assessee's appeal regarding disallowance of interest expenditure. The AO had disallowed interest claiming funds were diverted for non-business purposes. The assessee, engaged in manufacturing, trading and export of woolen carpets, maintained that interest expenditure in P&L account was exclusively for business purposes related to bank credit limits. Upon examining the ledger accounts, ITAT found that claimed interest expenditure was properly reflected in business accounts and was distinct from personal home loan interest paid to ICICI Bank Ltd. The tribunal concluded that the interest expenditure was legitimately incurred for business purposes, deleted the disallowance, and allowed the appeal in favor of the assessee.
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