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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HC dismissed Revenue's appeal, upholding the CIT(A) and ITAT orders allowing assessee's deduction under s.10A for its STP unit. HC held that the undertaking was not formed by "splitting up or reconstruction of a business already in existence" within the meaning of s.10A(2)(ii). The appellate authorities had recorded fact-based findings that the new unit involved substantial fresh investment and independent undertaking, despite being engaged in similar activity, and had correctly applied the governing legal principles. HC found no perversity in these factual findings and concluded that no substantial question of law arose for consideration. Consequently, the assessee's s.10A claim stood affirmed and the Revenue's appeal was rejected.
HC dismissed Revenue's appeal, upholding the CIT(A) and ITAT orders allowing assessee's deduction under s.10A for its STP unit. HC held that the undertaking was not formed by "splitting up or reconstruction of a business already in existence" within the meaning of s.10A(2)(ii). The appellate authorities had recorded fact-based findings that the new unit involved substantial fresh investment and independent undertaking, despite being engaged in similar activity, and had correctly applied the governing legal principles. HC found no perversity in these factual findings and concluded that no substantial question of law arose for consideration. Consequently, the assessee's s.10A claim stood affirmed and the Revenue's appeal was rejected.
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