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 remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench's prior basis point and the CIT(A)'s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)'s contrary deletion.
The ITAT remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench's prior basis point and the CIT(A)'s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)'s contrary deletion.
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