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 appeal and deleted the additions made by the AO and sustained by the CIT(A), holding that expenses were incurred wholly and exclusively for the assessee's business activities as a sole proprietor and as a working partner in two firms. The Tribunal found the AO's proportionate disallowance rested on an erroneous factual premise that the assessee was a working partner in only one firm; Revenue adduced no material to rebut the business nexus of the expenditures. Consequently the CIT(A)'s order sustaining the disallowance was set aside and the impugned additions deleted.
ITAT allowed the assessee's appeal and deleted the additions made by the AO and sustained by the CIT(A), holding that expenses were incurred wholly and exclusively for the assessee's business activities as a sole proprietor and as a working partner in two firms. The Tribunal found the AO's proportionate disallowance rested on an erroneous factual premise that the assessee was a working partner in only one firm; Revenue adduced no material to rebut the business nexus of the expenditures. Consequently the CIT(A)'s order sustaining the disallowance was set aside and the impugned additions deleted.
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