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 taxpayer's appeal for statistical purposes, remanding the matter to the Jurisdictional Assessing Officer for fresh examination. The tribunal held that the assessing authority erred in treating entire gross receipts as income under section 143(1) without considering allowable expenditures. The tribunal emphasized that income tax is chargeable on net income calculated per the Income Tax Act 1961, after deducting eligible expenditures under sections 37 or 57. The case was remitted back for verification of expenditure genuineness, with directions for reasonable opportunity of hearing to the assessee and substantiation of claims without unnecessary adjournments.
ITAT allowed the taxpayer's appeal for statistical purposes, remanding the matter to the Jurisdictional Assessing Officer for fresh examination. The tribunal held that the assessing authority erred in treating entire gross receipts as income under section 143(1) without considering allowable expenditures. The tribunal emphasized that income tax is chargeable on net income calculated per the Income Tax Act 1961, after deducting eligible expenditures under sections 37 or 57. The case was remitted back for verification of expenditure genuineness, with directions for reasonable opportunity of hearing to the assessee and substantiation of claims without unnecessary adjournments.
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