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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ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
ITAT held that deduction for additional employee cost is allowable for three assessment years under the statutory scheme and upheld CIT(A)'s allowance. It deleted interest disallowance under section 14A/Rule 8D because interest-free own funds exceeded exempt investments and Rule 8D's mechanical computation was unsustainable without AO's cogent dissatisfaction. The Tribunal found write back of creditors reflected in profit before tax, disallowing a fresh addition. AJIO marketing outlays were treated as revenue expenditure despite Ind AS capitalisation. Section 80G deductions operate independently of section 37(1) CSR disallowance and were allowed. Foreign tax credit claim filed before assessment completion was remitted for verification and grant by the AO.
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