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 upheld the Principal Commissioner's revision under section 263, finding the assessment order erroneous and prejudicial to the interests of the Revenue. It held that government grants relatable to depreciable assets must either reduce the actual cost/WDV of the asset or be brought to tax, and that the assessee's practice of crediting grants to a deferred account while claiming full depreciation occasioned an excess depreciation claim. The Tribunal rejected the assessee's contention based on accounting treatment and prior acceptance, found no infirmity in the Pr. CIT's order, and sustained the revisionary direction; the assessee's challenge was dismissed and relief refused.
The ITAT upheld the Principal Commissioner's revision under section 263, finding the assessment order erroneous and prejudicial to the interests of the Revenue. It held that government grants relatable to depreciable assets must either reduce the actual cost/WDV of the asset or be brought to tax, and that the assessee's practice of crediting grants to a deferred account while claiming full depreciation occasioned an excess depreciation claim. The Tribunal rejected the assessee's contention based on accounting treatment and prior acceptance, found no infirmity in the Pr. CIT's order, and sustained the revisionary direction; the assessee's challenge was dismissed and relief refused.
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