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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HC allowed the appeal, set aside the ITAT order and answered the substantial question in favour of the Assessee, holding that interest paid on borrowings used for lending to related concerns is allowable as a deduction against interest income for AY 1992-93. The Court held that "commencement of business" for Income Tax purposes occurs once preparatory acts (e.g. repairing/furnishing to make premises lettable) or financing activities are undertaken, and that lending constituted the Assessee's business (as per its MOA) rather than a fortuitous transaction. The HC reconciled the 1992-93 assessment with unchallenged findings for subsequent years and directed that interest expenditure be set off against interest receipts.
HC allowed the appeal, set aside the ITAT order and answered the substantial question in favour of the Assessee, holding that interest paid on borrowings used for lending to related concerns is allowable as a deduction against interest income for AY 1992-93. The Court held that "commencement of business" for Income Tax purposes occurs once preparatory acts (e.g. repairing/furnishing to make premises lettable) or financing activities are undertaken, and that lending constituted the Assessee's business (as per its MOA) rather than a fortuitous transaction. The HC reconciled the 1992-93 assessment with unchallenged findings for subsequent years and directed that interest expenditure be set off against interest receipts.
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