Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The ITAT upheld the CIT(A)'s reduction of disallowance on work-in-progress (WIP) expenses to 10%, finding the revenue's arbitrary adoption of this percentage without objective data impermissible, thereby allowing the assessee's ground and dismissing the revenue's claim. Regarding interest paid to a partner on capital introduced, the tribunal found the assessee's claim substantiated with adequate documentation and no evidence provided by the AO to prove the interest rate was excessive or unreasonable. The interest paid at 10.7% was deemed a legitimate financial cost integral to the project's sustenance. Consequently, the addition made by the AO was set aside, and the revenue's ground was rejected. Thus, both appeals by the revenue were dismissed, affirming the CIT(A)'s orders in favor of the assessee.
The ITAT upheld the CIT(A)'s reduction of disallowance on work-in-progress (WIP) expenses to 10%, finding the revenue's arbitrary adoption of this percentage without objective data impermissible, thereby allowing the assessee's ground and dismissing the revenue's claim. Regarding interest paid to a partner on capital introduced, the tribunal found the assessee's claim substantiated with adequate documentation and no evidence provided by the AO to prove the interest rate was excessive or unreasonable. The interest paid at 10.7% was deemed a legitimate financial cost integral to the project's sustenance. Consequently, the addition made by the AO was set aside, and the revenue's ground was rejected. Thus, both appeals by the revenue were dismissed, affirming the CIT(A)'s orders in favor of the assessee.
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