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 dismissed the Revenue's appeal and held that the assessee is entitled to deduction under s. 80IA(4) of the Act. The Tribunal found that the airport operators, being subject to control and monitoring by the Airports Authority of India and performing state functions pursuant to concession/OMDA arrangements, qualify as statutory authorities within the meaning of s. 80IA(4)(b). The Tribunal further held that the assessee's provision of ground-handling services constitutes the development, maintenance and operation of an infrastructure facility essential to airport functioning, bringing it within s. 80IA(4)(b) and (c). Consequently, the disallowance of the deduction was reversed and the appeal of the Revenue dismissed.
ITAT dismissed the Revenue's appeal and held that the assessee is entitled to deduction under s. 80IA(4) of the Act. The Tribunal found that the airport operators, being subject to control and monitoring by the Airports Authority of India and performing state functions pursuant to concession/OMDA arrangements, qualify as statutory authorities within the meaning of s. 80IA(4)(b). The Tribunal further held that the assessee's provision of ground-handling services constitutes the development, maintenance and operation of an infrastructure facility essential to airport functioning, bringing it within s. 80IA(4)(b) and (c). Consequently, the disallowance of the deduction was reversed and the appeal of the Revenue dismissed.
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