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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s treatment of surrendered survey income as business income taxable at normal rates rather than under special rates. The tribunal held that where the AO had earlier accepted, in the assessment for AY 2017-18, that additional amounts declared during survey were business receipts chargeable at normal rates, the Revenue could not reclassify identical surrender in the subsequent year under section 69B read with section 115BBE absent a change in material facts. The ITAT found no infirmity in deletion of tax computed at special rates for excess stock and expenditure, and affirmed the deletion of additions made under sections 69B/69C r.w.s.115BBE.
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s treatment of surrendered survey income as business income taxable at normal rates rather than under special rates. The tribunal held that where the AO had earlier accepted, in the assessment for AY 2017-18, that additional amounts declared during survey were business receipts chargeable at normal rates, the Revenue could not reclassify identical surrender in the subsequent year under section 69B read with section 115BBE absent a change in material facts. The ITAT found no infirmity in deletion of tax computed at special rates for excess stock and expenditure, and affirmed the deletion of additions made under sections 69B/69C r.w.s.115BBE.
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