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 CIT(A)'s decision disallowing the expenditure incurred on a study for optimizing freight costs, which was initially accounted as a provision for capital work in progress and later written off as other expenditure following project abandonment. The tribunal agreed that such expenditure does not qualify as capital expenditure or an unascertained liability. It was clarified that the assessee added back the amount in the computation of book profit under Section 115JB as a diminution in value of investments, consistent with the statutory explanation, and not as an unascertained liability. Consequently, the Revenue's appeal was dismissed, affirming the disallowance and the treatment of the expenditure in the assessee's financials.
The ITAT upheld the CIT(A)'s decision disallowing the expenditure incurred on a study for optimizing freight costs, which was initially accounted as a provision for capital work in progress and later written off as other expenditure following project abandonment. The tribunal agreed that such expenditure does not qualify as capital expenditure or an unascertained liability. It was clarified that the assessee added back the amount in the computation of book profit under Section 115JB as a diminution in value of investments, consistent with the statutory explanation, and not as an unascertained liability. Consequently, the Revenue's appeal was dismissed, affirming the disallowance and the treatment of the expenditure in the assessee's financials.
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