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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Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
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