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 allowed the assessee's claim for deduction under s.80P(2)(a)(i) in respect of interest income of Rs.12,05,115, directing that the AO grant the deduction (noting no justification to withhold the residual 10.86% where 89.14% was already admitted). The Tribunal observed that, pursuant to binding Supreme Court precedent, only profits and gains attributable to transactions with non-members are ineligible for s.80P relief; interest income remains allowable. The Tribunal remitted the matter on the contested gross profit addition from fertiliser/PDS sales, noting the AO failed to account for operating expenditures; it directed the AO to examine the assessee's expenditures, determine the net profit or loss from those activities, and then recompute the allowable s.80P deduction.
ITAT allowed the assessee's claim for deduction under s.80P(2)(a)(i) in respect of interest income of Rs.12,05,115, directing that the AO grant the deduction (noting no justification to withhold the residual 10.86% where 89.14% was already admitted). The Tribunal observed that, pursuant to binding Supreme Court precedent, only profits and gains attributable to transactions with non-members are ineligible for s.80P relief; interest income remains allowable. The Tribunal remitted the matter on the contested gross profit addition from fertiliser/PDS sales, noting the AO failed to account for operating expenditures; it directed the AO to examine the assessee's expenditures, determine the net profit or loss from those activities, and then recompute the allowable s.80P deduction.
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