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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Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
Selection of a notice under section 143(2) for limited scrutiny was valid because it targeted verification of a claim for deduction, and that ground of appeal was dismissed. The assessees' claim for deduction under 80P as a members' credit cooperative society was sustained by reliance on High Court precedents; the AO is directed to allow the deduction. Interest income derived from providing credit to members should be treated as business income and allowed as a deduction under the cooperative-deduction head rather than under an alternate head; AO is directed to grant deduction accordingly. Accounting provisions for interest and mandated provisioning for non performing advances comply with accrual accounting and statutory mandates, and related disallowances are deleted.
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