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 CIT(A)'s allowance of the assessee's claim for deduction under s.80IA(4) in respect of income from container freight stations, dismissing the revenue's appeals for AY 2018-19 and 2020-21. The Tribunal held that the AO's disallowance was untenable where no distinguishing facts for the year under consideration were recorded and the issue had been previously adjudicated in the assessee's favor by a coordinate bench. In view of the CBDT clarification on the scope of s.80IA(4) and the binding ratio in the assessee's earlier proceedings, the ITAT declined to interfere with the appellate authority's order and dismissed the revenue's appeals.
The ITAT affirmed the CIT(A)'s allowance of the assessee's claim for deduction under s.80IA(4) in respect of income from container freight stations, dismissing the revenue's appeals for AY 2018-19 and 2020-21. The Tribunal held that the AO's disallowance was untenable where no distinguishing facts for the year under consideration were recorded and the issue had been previously adjudicated in the assessee's favor by a coordinate bench. In view of the CBDT clarification on the scope of s.80IA(4) and the binding ratio in the assessee's earlier proceedings, the ITAT declined to interfere with the appellate authority's order and dismissed the revenue's appeals.
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