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 held that the Assessing Officer acted within the bounds of limited scrutiny under CASS, rejecting the assessee's contention that the AO exceeded the prescribed scope; additions disallowing royalty payments (relating to scrap) and restrictions on carry-forward losses based on earlier s.143(3) assessments were sustained on merits. However, issues concerning disallowance under s.40(a) for royalty and SAP maintenance expenses, and the quantum of carry-forward losses insofar as they depend on contested additions in earlier years, were remitted to the file of the Ld. CIT(A) for reconsideration. The appeal was therefore partly allowed for statistical purposes.
ITAT held that the Assessing Officer acted within the bounds of limited scrutiny under CASS, rejecting the assessee's contention that the AO exceeded the prescribed scope; additions disallowing royalty payments (relating to scrap) and restrictions on carry-forward losses based on earlier s.143(3) assessments were sustained on merits. However, issues concerning disallowance under s.40(a) for royalty and SAP maintenance expenses, and the quantum of carry-forward losses insofar as they depend on contested additions in earlier years, were remitted to the file of the Ld. CIT(A) for reconsideration. The appeal was therefore partly allowed for statistical purposes.
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