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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Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
Revision under revisional jurisdiction challenged the deductibility of provisions for 'standard assets' claimed as bad and doubtful debts under the income tax deduction provision for banks. The Tribunal analysed the RBI Master Direction definition of standard assets and construed the deduction provision, noting conflicting coordinate bench decisions but following consistent precedents that allow provisions for standard assets. Applying those precedents, the Tribunal quashed the revisional proceedings insofar as they sought to disallow the provision and restored the assessment outcome favourable to the assessee for the relevant year.
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