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 Appellant's claim for deduction under section 80IA of the IT Act, holding that interest earned on fixed deposits and on TDS refunds was deductible as income "derived from" the eligible business. The court found the deposits were placed for business purposes (equipment replacement and crane acquisition) and not merely to park surplus funds, establishing a direct nexus between the interest and the eligible container-terminal operations. The HC reversed the assessing officer's treatment of such interest as "income from other sources," concluding the interest was incidental to and integrally connected with the eligible business and therefore eligible for s.80IA relief.
HC allowed the Appellant's claim for deduction under section 80IA of the IT Act, holding that interest earned on fixed deposits and on TDS refunds was deductible as income "derived from" the eligible business. The court found the deposits were placed for business purposes (equipment replacement and crane acquisition) and not merely to park surplus funds, establishing a direct nexus between the interest and the eligible container-terminal operations. The HC reversed the assessing officer's treatment of such interest as "income from other sources," concluding the interest was incidental to and integrally connected with the eligible business and therefore eligible for s.80IA relief.
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