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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Dispute concerns multiple corporate assessment adjustments: the tribunal held depreciation disallowance unsustainable where assets were purchased through banking channels, recorded in audited books and legitimately owned and used, and directed deletion. Warranty provision deduction was recalculated and remitted to the AO to grant the correct deductible amount. Rental receipts from trailer leasing were held to be business income, not income from house property, and relevant additions were deleted. Carry forward of losses was remitted for correct computation. TDS shortfall claims were ordered verified with submitted evidence. Addition on share premium was deleted as consideration received from a non-resident is outside the relevant taxable scope. Ad hoc disallowances on vehicle repairs and residual settlements were deleted; depreciation on plant and verification of put-to-use dates was directed to AO.
Dispute concerns multiple corporate assessment adjustments: the tribunal held depreciation disallowance unsustainable where assets were purchased through banking channels, recorded in audited books and legitimately owned and used, and directed deletion. Warranty provision deduction was recalculated and remitted to the AO to grant the correct deductible amount. Rental receipts from trailer leasing were held to be business income, not income from house property, and relevant additions were deleted. Carry forward of losses was remitted for correct computation. TDS shortfall claims were ordered verified with submitted evidence. Addition on share premium was deleted as consideration received from a non-resident is outside the relevant taxable scope. Ad hoc disallowances on vehicle repairs and residual settlements were deleted; depreciation on plant and verification of put-to-use dates was directed to AO.
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