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 appeal of the assessee, deleting the addition made on account of alleged under-reporting of duty drawback. ITAT held that the assessee's consistent and bona fide accounting policy of recognizing duty drawback income on receipt (cash) basis, in line with prudence and prevailing trade practice, is acceptable and does not distort true income. It noted that the assessee had substantiated the actual duty drawback received during the relevant year through ledgers and sample shipping bills and that there was no revenue leakage, as the timing difference arose solely from the method of accounting. Applying the principles of consistency and recognizing that the right to receive becomes taxable on receipt basis in such circumstances, ITAT concluded that the method followed was fair and valid. Consequently, the addition made by the lower authorities was set aside and the assessee's appeal was allowed in full.
ITAT allowed the appeal of the assessee, deleting the addition made on account of alleged under-reporting of duty drawback. ITAT held that the assessee's consistent and bona fide accounting policy of recognizing duty drawback income on receipt (cash) basis, in line with prudence and prevailing trade practice, is acceptable and does not distort true income. It noted that the assessee had substantiated the actual duty drawback received during the relevant year through ledgers and sample shipping bills and that there was no revenue leakage, as the timing difference arose solely from the method of accounting. Applying the principles of consistency and recognizing that the right to receive becomes taxable on receipt basis in such circumstances, ITAT concluded that the method followed was fair and valid. Consequently, the addition made by the lower authorities was set aside and the assessee's appeal was allowed in full.
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