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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ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
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