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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Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
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