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 ITAT reversed the AO's disallowance of software development and maintenance expenses, holding that the payments to TFMSS, supported by market quotations and genuine agreements, were legitimate business expenditures. It relied on precedent from an associate trust's case where identical disallowance was deleted. Regarding personal gifts recorded in the Gift Management System, the Tribunal held that the gifts received by Ms. Sharon Angel Dhinakaran, being below the threshold under section 56(2)(x)(a) and specifically attributed to her, could not be taxed in the Trust's hands. Consequently, the AO's addition of personal gifts to the Trust's income was deleted. The Tribunal allowed all grounds raised by the assessee, confirming the deductibility of software charges and excluding personal gifts from the Trust's taxable income.
The ITAT reversed the AO's disallowance of software development and maintenance expenses, holding that the payments to TFMSS, supported by market quotations and genuine agreements, were legitimate business expenditures. It relied on precedent from an associate trust's case where identical disallowance was deleted. Regarding personal gifts recorded in the Gift Management System, the Tribunal held that the gifts received by Ms. Sharon Angel Dhinakaran, being below the threshold under section 56(2)(x)(a) and specifically attributed to her, could not be taxed in the Trust's hands. Consequently, the AO's addition of personal gifts to the Trust's income was deleted. The Tribunal allowed all grounds raised by the assessee, confirming the deductibility of software charges and excluding personal gifts from the Trust's taxable income.
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