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 allows rectification under s.154 and directs that the previously taxed amount of Rs.7.66 crores, offered by the assessee in its return and taxed in AY 2015-16, shall not be recharacterised or re-added in the impugned assessment year. The Tribunal holds that income from testing/calibration and sponsored fees, computed on actual basis, having been subjected to tax earlier, must be excluded from current-year taxable income and any addition under s.11(1B) is unsustainable. AO is directed to reduce the assessed income accordingly, delete the impugned addition and delete the amount from the current-year computation after due verification, with adjustments to be given effect in the rectified assessment.
ITAT allows rectification under s.154 and directs that the previously taxed amount of Rs.7.66 crores, offered by the assessee in its return and taxed in AY 2015-16, shall not be recharacterised or re-added in the impugned assessment year. The Tribunal holds that income from testing/calibration and sponsored fees, computed on actual basis, having been subjected to tax earlier, must be excluded from current-year taxable income and any addition under s.11(1B) is unsustainable. AO is directed to reduce the assessed income accordingly, delete the impugned addition and delete the amount from the current-year computation after due verification, with adjustments to be given effect in the rectified assessment.
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