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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Interest income on fixed deposits was held not taxable because the assessee, being wholly owned and constituted to perform governmental functions as an instrumentality of the State, qualifies as "State" under Article 12 read with Article 289 of the Constitution; consequently, such interest was treated as not derived from a taxable trade or business and the corresponding addition was deleted. Grant-in-aid received from the State Government was also held non-taxable since it was received by the assessee in its capacity as an arm of the State for executing public projects, and the related addition was directed to be deleted. - ITAT
Interest income on fixed deposits was held not taxable because the assessee, being wholly owned and constituted to perform governmental functions as an instrumentality of the State, qualifies as "State" under Article 12 read with Article 289 of the Constitution; consequently, such interest was treated as not derived from a taxable trade or business and the corresponding addition was deleted. Grant-in-aid received from the State Government was also held non-taxable since it was received by the assessee in its capacity as an arm of the State for executing public projects, and the related addition was directed to be deleted. - ITAT
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