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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Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
Rental receipts from the assessee's property were held to retain the character of income from house property because the assessee had consistently offered them under that head in earlier scrutiny assessments and the Revenue gave no basis to treat them as business income; deduction under section 24(a) was therefore allowed. The Tribunal also held that expenditure on renovation and erection of a temporary office structure, supported by bills and vouchers, was incurred to facilitate business more efficiently and was not shown to create an enduring capital asset; depreciation on the temporary structure was accordingly allowable.
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