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 on motor accident compensation kept in a court-ordered fixed deposit under lien, pending challenge to the award, was held not taxable in the relevant year because the assessee neither received nor had any enforceable right to the interest amount. Applying ss. 56(2)(viii) and 145B(1), only interest "received" on compensation/enhanced compensation is deemed income of the year of receipt, not on accrual or on a hypothetical basis; hence neither substantive nor protective addition could stand. Consequentially, credit of TDS reflected against such interest was directed to be allowed to the assessee. - ITAT
Interest on motor accident compensation kept in a court-ordered fixed deposit under lien, pending challenge to the award, was held not taxable in the relevant year because the assessee neither received nor had any enforceable right to the interest amount. Applying ss. 56(2)(viii) and 145B(1), only interest "received" on compensation/enhanced compensation is deemed income of the year of receipt, not on accrual or on a hypothetical basis; hence neither substantive nor protective addition could stand. Consequentially, credit of TDS reflected against such interest was directed to be allowed to the assessee. - ITAT
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