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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The HC upheld the Tribunal's factual finding that the assessee's claimed expenditure for gratuity and leave encashment payments corresponded to actual disbursements made during the relevant year, not merely notional or anticipated liabilities. The Tribunal noted that the assessee had adjusted provisions in Schedule 16, reducing gratuity and leave encashment provisions by over Rs. 7 crore, thereby reflecting net amounts debited in the Profit & Loss Account as actual expenses incurred. Consequently, the disallowance based on differences between book valuations and actuarial valuations by LIC and SBI Life was rejected. The HC concluded that the taxable income computation rightly excluded notional provisions, recognizing only actual expenses. The appeal was dismissed, and no substantial question of law was found to warrant interference.
The HC upheld the Tribunal's factual finding that the assessee's claimed expenditure for gratuity and leave encashment payments corresponded to actual disbursements made during the relevant year, not merely notional or anticipated liabilities. The Tribunal noted that the assessee had adjusted provisions in Schedule 16, reducing gratuity and leave encashment provisions by over Rs. 7 crore, thereby reflecting net amounts debited in the Profit & Loss Account as actual expenses incurred. Consequently, the disallowance based on differences between book valuations and actuarial valuations by LIC and SBI Life was rejected. The HC concluded that the taxable income computation rightly excluded notional provisions, recognizing only actual expenses. The appeal was dismissed, and no substantial question of law was found to warrant interference.
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