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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Revenue's appeal before ITAT was dismissed. ITAT upheld CIT(A)'s acceptance of additional evidence under Rule 46A, noting that the material was remanded to the AO and no remand report was furnished despite repeated reminders; thus there was no violation of Rule 46A. On merits, ITAT sustained CIT(A)'s deletion of additions relating to discrepancies in sales turnover, trade payables, and current liabilities, finding that reconciliations, third-party confirmations under s.133(6), and supporting records fully justified the assessee's position. ITAT also affirmed deletion of addition towards exceptional charges/expenses, holding that the assessee had already made a suo motu disallowance under s.37 and any further disallowance would result in double addition.
Revenue's appeal before ITAT was dismissed. ITAT upheld CIT(A)'s acceptance of additional evidence under Rule 46A, noting that the material was remanded to the AO and no remand report was furnished despite repeated reminders; thus there was no violation of Rule 46A. On merits, ITAT sustained CIT(A)'s deletion of additions relating to discrepancies in sales turnover, trade payables, and current liabilities, finding that reconciliations, third-party confirmations under s.133(6), and supporting records fully justified the assessee's position. ITAT also affirmed deletion of addition towards exceptional charges/expenses, holding that the assessee had already made a suo motu disallowance under s.37 and any further disallowance would result in double addition.
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