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 appeal and upheld the CIT(A)'s orders: the amount characterized as an "arbitration award" was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue's challenge was therefore rejected in entirety.
ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s orders: the amount characterized as an "arbitration award" was held to be a typographical misclassification of software sale and the related addition was deleted; foreign exchange fluctuation gains were held to be business receipts directly relatable to export of software and therefore eligible for exemption under s.10A; and no disallowance under s.40(a)(ia) was warranted where the assessee had deducted tax at source (albeit at a lower rate) on the buy-back consideration, such deduction being treated as compliance with the TDS obligation. The Revenue's challenge was therefore rejected in entirety.
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