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 HC upheld the ITAT's finding that the assessment order was validly passed under Section 143(3) despite the erroneous reference to Section 147, holding that such misquotation is curable under Section 292B and does not invalidate the proceedings. The court rejected the CIT(A)'s interpretation that the order was under Section 147/148, affirming that the assessment was a regular scrutiny under Section 143(3). Regarding the computation of deductions under Section 80-IA, the HC ruled in favor of the assessee, holding that interest income earned in the ordinary course of business cannot be artificially segregated to deny the deduction. The court found the Revenue's attempt to bifurcate business income arbitrary and against commercial prudence. Additionally, the HC concurred with the ITAT that interest income arising from the business cannot be offset against interest paid, aligning with Supreme Court precedent, thereby affirming the assessee's entitlement to full deductions under Section 80-IA.
The HC upheld the ITAT's finding that the assessment order was validly passed under Section 143(3) despite the erroneous reference to Section 147, holding that such misquotation is curable under Section 292B and does not invalidate the proceedings. The court rejected the CIT(A)'s interpretation that the order was under Section 147/148, affirming that the assessment was a regular scrutiny under Section 143(3). Regarding the computation of deductions under Section 80-IA, the HC ruled in favor of the assessee, holding that interest income earned in the ordinary course of business cannot be artificially segregated to deny the deduction. The court found the Revenue's attempt to bifurcate business income arbitrary and against commercial prudence. Additionally, the HC concurred with the ITAT that interest income arising from the business cannot be offset against interest paid, aligning with Supreme Court precedent, thereby affirming the assessee's entitlement to full deductions under Section 80-IA.
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