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 upheld the CIT(A)'s deletions and allowed the appeal in favour of the assessee. The Tribunal held that disallowance of director's salary was unjustified: the director was a foreign national duly qualified, had rendered services, and had declared remuneration in her return, so the AO's addition was dismissed. Regarding rejection of books, ITAT found the AO had rejected accounts and made summary additions solely on observed declines in gross and net profit ratios without issuing specific queries, obtaining explanations, or recording cogent reasons or defects in maintenance of books; accordingly the assessments based on such summary rejections were set aside and the Revenue's grounds were dismissed.
ITAT upheld the CIT(A)'s deletions and allowed the appeal in favour of the assessee. The Tribunal held that disallowance of director's salary was unjustified: the director was a foreign national duly qualified, had rendered services, and had declared remuneration in her return, so the AO's addition was dismissed. Regarding rejection of books, ITAT found the AO had rejected accounts and made summary additions solely on observed declines in gross and net profit ratios without issuing specific queries, obtaining explanations, or recording cogent reasons or defects in maintenance of books; accordingly the assessments based on such summary rejections were set aside and the Revenue's grounds were dismissed.
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