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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Whether the assessee's investments in group/subsidiary companies constituted "business" so as to allow related expenditure and consequent set-off of loss was the dominant issue. The Tribunal held that the assessee's main object was to make strategic investments in such companies, and the investments made were in furtherance of that object; hence, the activity amounted to business within s.2(13) and the expenditure was incidental thereto, warranting allowance as business expenditure. Having accepted the resultant current-year business loss, the Tribunal directed that it be set off against interest income assessed under "Income from other sources" in accordance with s.71, and allowed the appeal. - ITAT
Whether the assessee's investments in group/subsidiary companies constituted "business" so as to allow related expenditure and consequent set-off of loss was the dominant issue. The Tribunal held that the assessee's main object was to make strategic investments in such companies, and the investments made were in furtherance of that object; hence, the activity amounted to business within s.2(13) and the expenditure was incidental thereto, warranting allowance as business expenditure. Having accepted the resultant current-year business loss, the Tribunal directed that it be set off against interest income assessed under "Income from other sources" in accordance with s.71, and allowed the appeal. - ITAT
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