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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Characterisation of Common Area Maintenance (CAM) charges as payments for services relating to upkeep, cleanliness, utilities and maintenance leads to their classification as contractual payments subject to TDS under Section 194C rather than as rent under Section 194I; the Tribunal applied this legal principle and deleted the assessment addition. The Tribunal relied on coordinate Bench precedents in the assessee's own case and noted that the High Court dismissed the Revenue's challenge to that line of decisions, reinforcing that CAM charges cannot be characterised as rent and that the Revenue's appeal must be dismissed for the year under review.
Characterisation of Common Area Maintenance (CAM) charges as payments for services relating to upkeep, cleanliness, utilities and maintenance leads to their classification as contractual payments subject to TDS under Section 194C rather than as rent under Section 194I; the Tribunal applied this legal principle and deleted the assessment addition. The Tribunal relied on coordinate Bench precedents in the assessee's own case and noted that the High Court dismissed the Revenue's challenge to that line of decisions, reinforcing that CAM charges cannot be characterised as rent and that the Revenue's appeal must be dismissed for the year under review.
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