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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Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
Admissibility of additional evidence submitted during remand reconciled GSTR 1 entries with profit and loss turnover, leading to deletion of a turnover discrepancy addition because the Assessing Officer's remand report attributed the variance to earlier years. Recognition of interest on service concession receivable and deferred retention liability in the profit and loss account was treated as notional income recorded to comply with accounting standards (IND AS) and not taxable as actual income in the relevant year; the Tribunal sustained deletion of the section 56 addition, noting subsequent assessments accepted actual annuity interest treatment. Revenue appeal dismissed on both points.
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