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 upheld the allowance of contributions to the Core Settlement Guarantee Fund as deductible business expenditure. The assessee, a clearing corporation wholly owned by a stock exchange, established the Core SGF pursuant to SEBI directions to ensure unconditional availability of funds for settlement obligations. Revenue disallowed the contributions and the CIT(A) sustained the disallowance, but a co-ordinate Bench had earlier ruled in favour of the parent entity on the same issue for other assessment years. Applying that precedent, the ITAT held the contributions were incurred wholly and exclusively for the purpose of business and allowed the deduction, deciding the appeals in favour of the assessee.
The ITAT upheld the allowance of contributions to the Core Settlement Guarantee Fund as deductible business expenditure. The assessee, a clearing corporation wholly owned by a stock exchange, established the Core SGF pursuant to SEBI directions to ensure unconditional availability of funds for settlement obligations. Revenue disallowed the contributions and the CIT(A) sustained the disallowance, but a co-ordinate Bench had earlier ruled in favour of the parent entity on the same issue for other assessment years. Applying that precedent, the ITAT held the contributions were incurred wholly and exclusively for the purpose of business and allowed the deduction, deciding the appeals in favour of the assessee.
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