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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The ITAT partly allowed the appeal of the assessee: for transfer pricing the AO is directed to adopt interest on outstanding receivables from AEs at LIBOR + 2% (TPO's LIBOR + 4% disallowed); corporate guarantee commission benchmarking limited to 0.5%; addition for alleged bogus purchases reduced and confirmed only to the actual transaction amount of Rs. 7,22,178 with directions to give effect. Claim for deduction under s.35(2AB) (R&D) is restored to the file of the AO for fresh adjudication in light of Form 3CL dated 20.08.2024. Donations from CSR funds are permitted for s.80G deduction subject to statutory eligibility and verification by the AO; matter remitted for fresh decision.
The ITAT partly allowed the appeal of the assessee: for transfer pricing the AO is directed to adopt interest on outstanding receivables from AEs at LIBOR + 2% (TPO's LIBOR + 4% disallowed); corporate guarantee commission benchmarking limited to 0.5%; addition for alleged bogus purchases reduced and confirmed only to the actual transaction amount of Rs. 7,22,178 with directions to give effect. Claim for deduction under s.35(2AB) (R&D) is restored to the file of the AO for fresh adjudication in light of Form 3CL dated 20.08.2024. Donations from CSR funds are permitted for s.80G deduction subject to statutory eligibility and verification by the AO; matter remitted for fresh decision.
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