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 assessee's appeal, holding that the amendment to section 11(3) introduced by the Finance Act, 2022 is prospective and does not affect accumulated income relating to FY 2016-17 and FY 2017-18. The Tribunal observed that the assessee utilized Rs. 35,66,540 within the prescribed six-year period for FY 2016-17, and the remaining unutilized amount was voluntarily offered in the return, thus disallowing taxation of this income in AY 2023-24. For FY 2017-18, the assessee retains the time window until 31-03-2024 to utilize the accumulated income, precluding taxation in the impugned year. The Tribunal set aside the additions of Rs. 35,66,540 and Rs. 40,00,000 related to FYs 2016-17 and 2017-18 respectively, affirming that the Finance Act, 2022 amendments apply only to fresh accumulations post 1st April 2022.
The ITAT allowed the assessee's appeal, holding that the amendment to section 11(3) introduced by the Finance Act, 2022 is prospective and does not affect accumulated income relating to FY 2016-17 and FY 2017-18. The Tribunal observed that the assessee utilized Rs. 35,66,540 within the prescribed six-year period for FY 2016-17, and the remaining unutilized amount was voluntarily offered in the return, thus disallowing taxation of this income in AY 2023-24. For FY 2017-18, the assessee retains the time window until 31-03-2024 to utilize the accumulated income, precluding taxation in the impugned year. The Tribunal set aside the additions of Rs. 35,66,540 and Rs. 40,00,000 related to FYs 2016-17 and 2017-18 respectively, affirming that the Finance Act, 2022 amendments apply only to fresh accumulations post 1st April 2022.
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