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 dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
ITAT dismissed the revenue's grounds challenging classification of expenditures on dies, moulds, jigs, fixtures and software as revenue in nature and allowable as deductions; penalty receipts from suppliers were held to be capital receipts and that ground was dismissed. The Tribunal directed deletion of impugned additions, upheld proportionate amortisation of non-refundable premium on 99-year leasehold land, and sustained prior-period charging of crystallised liabilities. Section 80IA deduction was allowed without adjustment for pre-assessment year depreciation and losses. Section 14A disallowance was deleted except administrative disallowance limited to 2% of exempt income. Transfer-pricing and doubtful-debts issues were remitted to AO/TPO for fresh consideration in accordance with law.
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