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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ITAT held that the alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
ITAT held that the alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
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