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 assessee's consistent accounting method of claiming revenue expenditure deductions, rejecting the revenue's disallowance of 90% of such expenditure as ad-hoc. The Tribunal recognized that the expenditures were wholly and exclusively incurred for business purposes and linked to the project, which had not yet generated revenue. Consequently, these costs should be treated as part of project cost or inventory and not disallowed outright. The ITAT noted prior acceptance of this accounting approach by the revenue in earlier assessments, except for finance costs, and affirmed that the disputed deductions for the relevant years were allowable. The consistent application and recognition of these expenses as business expenditures entitled the assessee to the claimed deductions for the assessment year under appeal.
The ITAT upheld the assessee's consistent accounting method of claiming revenue expenditure deductions, rejecting the revenue's disallowance of 90% of such expenditure as ad-hoc. The Tribunal recognized that the expenditures were wholly and exclusively incurred for business purposes and linked to the project, which had not yet generated revenue. Consequently, these costs should be treated as part of project cost or inventory and not disallowed outright. The ITAT noted prior acceptance of this accounting approach by the revenue in earlier assessments, except for finance costs, and affirmed that the disputed deductions for the relevant years were allowable. The consistent application and recognition of these expenses as business expenditures entitled the assessee to the claimed deductions for the assessment year under appeal.
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