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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The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
The ITAT affirmed the appellate order deleting the impugned ad hoc disallowance made by the AO, holding that the AO had not impugned the genuineness of the expenses and had failed to appreciate their nexus with the assessee's business (including increased repair and maintenance following acquisition of two additional vessels and legitimate tour expenses). The Tribunal further sustained deletion of the proposed addition relating to alleged excess purchase value of vessels, finding the carrying value in the transferor's audited accounts duly substantiated, independent valuation unchallenged by the revenue, and recorded cost lower than original purchase price (with rupee devaluation affecting resultant cost); consequently no inflated cost or excess depreciation was established.
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