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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Section 56(2)(ix) addition on alleged forfeited advance was held unsustainable because the amount received was not an "advance" for transfer of a capital asset but reimbursement/recovery of amounts earlier paid on behalf of the payer; the statutory precondition of receipt of advance was not met, so the addition was deleted. Disallowance under section 57 was rejected since the assessee had disclosed bank interest income and the bank transaction charges were incurred for earning such income and were supported by details; the deduction was allowed. Capital gains computation was corrected as the AO restricted cost of acquisition without reasons or breakup; full claimed cost was accepted, resulting in the declared capital loss being allowed. - ITAT
Section 56(2)(ix) addition on alleged forfeited advance was held unsustainable because the amount received was not an "advance" for transfer of a capital asset but reimbursement/recovery of amounts earlier paid on behalf of the payer; the statutory precondition of receipt of advance was not met, so the addition was deleted. Disallowance under section 57 was rejected since the assessee had disclosed bank interest income and the bank transaction charges were incurred for earning such income and were supported by details; the deduction was allowed. Capital gains computation was corrected as the AO restricted cost of acquisition without reasons or breakup; full claimed cost was accepted, resulting in the declared capital loss being allowed. - ITAT
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