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 upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable.
ITAT upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable.
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