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. It held that, for transfer pricing/section 80-IA(10)/80-IC purposes, the operating profit margin of the manufacturing unit located in a backward area of Himachal Pradesh must be computed excluding the benefit of excise duty and CST waivers, following the coordinate bench view that excise duty, sales tax and income tax are to be excluded from operating profits. Further, ITAT accepted the assessee's additional ground that excise duty exemption availed in the 10th year of operations constituted a capital receipt, relying on HC precedent treating such subsidies/exemptions, granted to promote industrial development and employment generation, as capital in nature while computing income under normal provisions.
ITAT allowed the assessee's appeal. It held that, for transfer pricing/section 80-IA(10)/80-IC purposes, the operating profit margin of the manufacturing unit located in a backward area of Himachal Pradesh must be computed excluding the benefit of excise duty and CST waivers, following the coordinate bench view that excise duty, sales tax and income tax are to be excluded from operating profits. Further, ITAT accepted the assessee's additional ground that excise duty exemption availed in the 10th year of operations constituted a capital receipt, relying on HC precedent treating such subsidies/exemptions, granted to promote industrial development and employment generation, as capital in nature while computing income under normal provisions.
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