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 appeal, holding that the AO's recharacterization of business income as "income from other sources" was legally unsustainable without contrary material evidence. The assessee, a software and networking solutions company, had legitimate revenue from identifiable clients under valid tax invoices. The AO failed to produce incriminating material during search or evidence contradicting the business activities. The tribunal emphasized that quantum of income does not determine business genuineness, noting the assessee's consistent IT business operations accepted in prior assessments. The disallowance of business expenses was unjustified absent findings of bogus or unrelated expenditure. Applying the principle of consistency from Radhasoami Satsang, the tribunal ruled that treatment accepted in earlier years should not be disturbed without factual changes, directing deletion of additions totaling the disputed amounts.
ITAT allowed the appeal, holding that the AO's recharacterization of business income as "income from other sources" was legally unsustainable without contrary material evidence. The assessee, a software and networking solutions company, had legitimate revenue from identifiable clients under valid tax invoices. The AO failed to produce incriminating material during search or evidence contradicting the business activities. The tribunal emphasized that quantum of income does not determine business genuineness, noting the assessee's consistent IT business operations accepted in prior assessments. The disallowance of business expenses was unjustified absent findings of bogus or unrelated expenditure. Applying the principle of consistency from Radhasoami Satsang, the tribunal ruled that treatment accepted in earlier years should not be disturbed without factual changes, directing deletion of additions totaling the disputed amounts.
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