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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Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
Disallowance of expenses apportioned to rented portions was contested where corresponding recoveries (power charges and CAM/maintenance) were recorded as business income. Applying the matching principle and prior coordinate bench decisions on identical facts, the ITAT held that apportioned power and fuel expenses and proportionate repair and maintenance charges need not be disallowed when recovered from tenants and reflected as business income; accordingly the Tribunal deleted the AO's additions in respect of both categories of expenses.
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