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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Expenditure relating to a discontinued business remained allowable where the assessee had separately disclosed the operation, revenue, expenses and loss in audited financial statements and notes to accounts, and the Assessing Officer had found no item to be unvouched, unsupported or not for business purposes. The Tribunal held that such loss could not be curtailed on a proportionate basis merely because the common expenses were not submitted to the slump sale valuer. The valuation report was relevant only for capital gains computation and did not govern deductibility under section 37(1). The Revenue's challenge failed and the deletion of the disallowance was upheld.
Expenditure relating to a discontinued business remained allowable where the assessee had separately disclosed the operation, revenue, expenses and loss in audited financial statements and notes to accounts, and the Assessing Officer had found no item to be unvouched, unsupported or not for business purposes. The Tribunal held that such loss could not be curtailed on a proportionate basis merely because the common expenses were not submitted to the slump sale valuer. The valuation report was relevant only for capital gains computation and did not govern deductibility under section 37(1). The Revenue's challenge failed and the deletion of the disallowance was upheld.
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