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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT remanded the matter to the AO for fresh adjudication regarding the disallowance of bad debts written off on advances made by the appellant to movie producers. The tribunal held that the AO's summary acceptance of the returned income without discussing the disallowance issue was insufficient. While advances given in the normal course of business and subsequent written off losses are deductible under section 36, the appellant failed to produce evidence that interest income on such advances was previously offered as business income. Therefore, the connection between the advances and business activities requires verification. The appeal was allowed for statistical purposes, directing the AO to re-examine the nature of the loans and related tax treatment of interest income to determine the deductibility of the bad debts.
The ITAT remanded the matter to the AO for fresh adjudication regarding the disallowance of bad debts written off on advances made by the appellant to movie producers. The tribunal held that the AO's summary acceptance of the returned income without discussing the disallowance issue was insufficient. While advances given in the normal course of business and subsequent written off losses are deductible under section 36, the appellant failed to produce evidence that interest income on such advances was previously offered as business income. Therefore, the connection between the advances and business activities requires verification. The appeal was allowed for statistical purposes, directing the AO to re-examine the nature of the loans and related tax treatment of interest income to determine the deductibility of the bad debts.
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