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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Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
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