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 allowed the assessee's appeal for statistical purposes and remitted the issue to the AO for fresh adjudication on the claim for proportionate deduction under s.57 of the Act. The Tribunal held that a deduction for expenses attributable to interest income may be permitted only upon the assessee establishing a direct nexus between the expenditure incurred and the earning of interest from nationalized banks. The Tribunal distinguished an earlier decision relied upon by the assessee on the basis that the income profile there (predominantly rental) differed materially from the present facts. The AO is directed to reconsider the claim in light of the required nexus.
The ITAT allowed the assessee's appeal for statistical purposes and remitted the issue to the AO for fresh adjudication on the claim for proportionate deduction under s.57 of the Act. The Tribunal held that a deduction for expenses attributable to interest income may be permitted only upon the assessee establishing a direct nexus between the expenditure incurred and the earning of interest from nationalized banks. The Tribunal distinguished an earlier decision relied upon by the assessee on the basis that the income profile there (predominantly rental) differed materially from the present facts. The AO is directed to reconsider the claim in light of the required nexus.
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