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 held that interest received by the assessee on enhanced compensation consequent to compulsory acquisition does not constitute taxable income under s.56(2)(viii) read with s.145B(1); the Assessing Officer's inclusion of 50% of such interest as income was set aside. Noting divergent High Court rulings, the Tribunal, guided by prevailing Supreme Court principle favoring the assessee where conflicts exist, aligned with the decisions favorable to the assessee and allowed the appeal. Assessment treating the disputed interest as income was therefore reversed and the matter remitted/treated in accordance with this determination.
ITAT held that interest received by the assessee on enhanced compensation consequent to compulsory acquisition does not constitute taxable income under s.56(2)(viii) read with s.145B(1); the Assessing Officer's inclusion of 50% of such interest as income was set aside. Noting divergent High Court rulings, the Tribunal, guided by prevailing Supreme Court principle favoring the assessee where conflicts exist, aligned with the decisions favorable to the assessee and allowed the appeal. Assessment treating the disputed interest as income was therefore reversed and the matter remitted/treated in accordance with this determination.
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