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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC upheld ITAT's dismissal of Revenue's appeals concerning deduction under Section 10A for AYs 2007-08 and 2008-09. It affirmed the CIT(A)'s finding that the AO was not justified in reallocating royalty and management fee expenses, incurred by non-10A units and paid to an overseas group entity, to 10A-eligible captive units based on revenue apportionment. The HC held that such expenses, linked to third-party revenue and services of group entities, could not be attributed to captive 10A units, and that additional allocation of legal and professional expenses was unwarranted. Consequently, disallowance of Section 10A deduction was rightly deleted and Revenue's appeals were dismissed.
HC upheld ITAT's dismissal of Revenue's appeals concerning deduction under Section 10A for AYs 2007-08 and 2008-09. It affirmed the CIT(A)'s finding that the AO was not justified in reallocating royalty and management fee expenses, incurred by non-10A units and paid to an overseas group entity, to 10A-eligible captive units based on revenue apportionment. The HC held that such expenses, linked to third-party revenue and services of group entities, could not be attributed to captive 10A units, and that additional allocation of legal and professional expenses was unwarranted. Consequently, disallowance of Section 10A deduction was rightly deleted and Revenue's appeals were dismissed.
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