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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT allowed the assessee's appeal and directed deletion of the impugned addition, holding that the assessee qualifies for deduction under s. 80IB(2). The Tribunal found the first limb satisfied, concluding the assessee was engaged in manufacturing activity despite revenue's characterization. The second limb was satisfied on the basis of the AO's remand report which categorically found use of new plant and machinery. The third limb-engagement of ten or more persons in the undertaking while using power-was held satisfied on the factual matrix, including the contractual arrangement for ancillary workers and maintenance of a specific wages register. The additions by the AO and confirmation by the CIT(A) were set aside and matter remitted for compliance with this direction.
ITAT allowed the assessee's appeal and directed deletion of the impugned addition, holding that the assessee qualifies for deduction under s. 80IB(2). The Tribunal found the first limb satisfied, concluding the assessee was engaged in manufacturing activity despite revenue's characterization. The second limb was satisfied on the basis of the AO's remand report which categorically found use of new plant and machinery. The third limb-engagement of ten or more persons in the undertaking while using power-was held satisfied on the factual matrix, including the contractual arrangement for ancillary workers and maintenance of a specific wages register. The additions by the AO and confirmation by the CIT(A) were set aside and matter remitted for compliance with this direction.
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