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 held that prior period and extraordinary items, though separately disclosed under Section 115JA(2) read with Section 211 of the Companies Act, form an integral component of net profit for the purposes of MAT computation under Section 115JB. The assessee's approach of not adding back prior period expenses to book profits was upheld since these items were already subsumed within the net profit figure, and their separate disclosure was intended solely for transparency regarding their impact on current profits. The tribunal rejected the notion that the net profit should be computed excluding such items. Consequently, the assessee was not required to make any further adjustments in the book profit computation under Section 115JB, and the appeal was allowed in favor of the assessee.
The ITAT held that prior period and extraordinary items, though separately disclosed under Section 115JA(2) read with Section 211 of the Companies Act, form an integral component of net profit for the purposes of MAT computation under Section 115JB. The assessee's approach of not adding back prior period expenses to book profits was upheld since these items were already subsumed within the net profit figure, and their separate disclosure was intended solely for transparency regarding their impact on current profits. The tribunal rejected the notion that the net profit should be computed excluding such items. Consequently, the assessee was not required to make any further adjustments in the book profit computation under Section 115JB, and the appeal was allowed in favor of the assessee.
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