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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The ITAT upheld the CIT(A)'s order deleting additions made by the AO. On closing stock under the Percentage Completion Method, it affirmed that there was no dispute on project parameters and that the difference arose solely from the AO's computational error in recognizing turnover, warranting deletion of the addition. Regarding addition under s.43CA on sale of immovable property, the ITAT agreed that stamp duty valuation must correspond to the year of the agreement to sell, not the subsequent sale deed, and found no error in CIT(A) accepting additional evidence. Further, interest on service tax and TDS was held compensatory, not penal, and allowable as deduction.
The ITAT upheld the CIT(A)'s order deleting additions made by the AO. On closing stock under the Percentage Completion Method, it affirmed that there was no dispute on project parameters and that the difference arose solely from the AO's computational error in recognizing turnover, warranting deletion of the addition. Regarding addition under s.43CA on sale of immovable property, the ITAT agreed that stamp duty valuation must correspond to the year of the agreement to sell, not the subsequent sale deed, and found no error in CIT(A) accepting additional evidence. Further, interest on service tax and TDS was held compensatory, not penal, and allowable as deduction.
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