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 upheld the rectification order under section 154, revising the assessee's total income to INR 53,16,66,580 from the originally declared INR 52,04,08,740, directing the AO to replace the income figure of INR 58,29,98,519 used in the final assessment with the rectified amount. The tribunal allowed the appeal on this ground. Regarding the addition under section 43B for leave encashment, the ITAT observed that although the CPC disallowed INR 94,88,237, the Tax Audit Report showed payment of INR 48,77,017 made before the due date for filing the return. The AO was directed to verify these payments and allow the claim as per the provisions of section 43B. The order mandates conformity to the rectified income and proper allowance of payments made within the statutory timeline.
The ITAT upheld the rectification order under section 154, revising the assessee's total income to INR 53,16,66,580 from the originally declared INR 52,04,08,740, directing the AO to replace the income figure of INR 58,29,98,519 used in the final assessment with the rectified amount. The tribunal allowed the appeal on this ground. Regarding the addition under section 43B for leave encashment, the ITAT observed that although the CPC disallowed INR 94,88,237, the Tax Audit Report showed payment of INR 48,77,017 made before the due date for filing the return. The AO was directed to verify these payments and allow the claim as per the provisions of section 43B. The order mandates conformity to the rectified income and proper allowance of payments made within the statutory timeline.
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