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 assessee's accounting treatment, disallowing the tax authorities' rejection of lease equalization charges and related depreciation adjustments. The Tribunal found the assessee had consistently followed the ICAI Guidelines on accounting for leases, separately disclosing lease rentals and matching lease annual charges in the profit and loss account; where annual lease charges fell below minimum statutory depreciation the excess was claimed as expenditure, to be reversed or credited when annual charges exceed statutory depreciation. As a regularly followed, declared accounting policy producing revenue neutrality across assessment years, the treatment is acceptable for tax purposes. Accordingly, the contested grounds were allowed and the disallowances set aside.
ITAT upheld the assessee's accounting treatment, disallowing the tax authorities' rejection of lease equalization charges and related depreciation adjustments. The Tribunal found the assessee had consistently followed the ICAI Guidelines on accounting for leases, separately disclosing lease rentals and matching lease annual charges in the profit and loss account; where annual lease charges fell below minimum statutory depreciation the excess was claimed as expenditure, to be reversed or credited when annual charges exceed statutory depreciation. As a regularly followed, declared accounting policy producing revenue neutrality across assessment years, the treatment is acceptable for tax purposes. Accordingly, the contested grounds were allowed and the disallowances set aside.
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