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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ITAT allowed the assessee's appeal, holding that conversion of grapes into raisins constituted an agricultural activity. The Tribunal found no evidence to rebut the assessee's factual claim of using traditional conversion methods, noted prior revenue acceptance of such conversion as agricultural income in AY 2018-19, and relied on a governmental circular indicating an agriculturist supplying raisins is exempt from GST registration. Consequently, the Tribunal held the Assessing Officer's bifurcation of total agricultural receipts on a 60:40 basis - treating 60% as business income - was unsustainable, directed deletion of the 60% addition, and remitted the assessment adjustment accordingly.
ITAT allowed the assessee's appeal, holding that conversion of grapes into raisins constituted an agricultural activity. The Tribunal found no evidence to rebut the assessee's factual claim of using traditional conversion methods, noted prior revenue acceptance of such conversion as agricultural income in AY 2018-19, and relied on a governmental circular indicating an agriculturist supplying raisins is exempt from GST registration. Consequently, the Tribunal held the Assessing Officer's bifurcation of total agricultural receipts on a 60:40 basis - treating 60% as business income - was unsustainable, directed deletion of the 60% addition, and remitted the assessment adjustment accordingly.
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