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 allowed the deduction of interest on late payment of TDS as a business expenditure under section 37(1), rejecting the Revenue's classification of TDS as income tax under section 40(a)(ii). Sales promotion expenses disallowed by the AO were restored, as the assessee adequately substantiated that the expenses were wholly and exclusively for business purposes. The claim for 100% depreciation on iron hoardings was upheld, recognizing their enduring benefit and aligning with precedent favoring the assessee. Prior period expenses were allowed. The assessee's claim for deduction under section 80IA was affirmed, with the Tribunal confirming the assessee's status as an infrastructure developer engaged in constructing foot over bridges and bus shelters, thereby entitling it to the deduction, contrary to the Revenue's assertion that it was merely an advertising firm.
The ITAT allowed the deduction of interest on late payment of TDS as a business expenditure under section 37(1), rejecting the Revenue's classification of TDS as income tax under section 40(a)(ii). Sales promotion expenses disallowed by the AO were restored, as the assessee adequately substantiated that the expenses were wholly and exclusively for business purposes. The claim for 100% depreciation on iron hoardings was upheld, recognizing their enduring benefit and aligning with precedent favoring the assessee. Prior period expenses were allowed. The assessee's claim for deduction under section 80IA was affirmed, with the Tribunal confirming the assessee's status as an infrastructure developer engaged in constructing foot over bridges and bus shelters, thereby entitling it to the deduction, contrary to the Revenue's assertion that it was merely an advertising firm.
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