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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The Tribunal addressed multiple tax adjustments in telecom operations, deleting disallowances under section 40(a)(ia) for distributor discounts and under section 40(a)(i) for interconnect usage charges by following binding precedent in the assessee's own earlier years. It allowed amortisation of one-time 3G and BWA spectrum payments under section 35ABB on the basis that the right to operate telecom services had been acquired and the spectrum was put to use, and it deleted related enhancement and depreciation disallowance as a double adjustment. It also held that principal loan repayments were outside section 43B, removed additions based on inventory and internal reconciliation differences, upheld deletion of the DoT current account addition, and deleted section 14A disallowance because no exempt income was received. One TDS-related issue was remitted for verification.
The Tribunal addressed multiple tax adjustments in telecom operations, deleting disallowances under section 40(a)(ia) for distributor discounts and under section 40(a)(i) for interconnect usage charges by following binding precedent in the assessee's own earlier years. It allowed amortisation of one-time 3G and BWA spectrum payments under section 35ABB on the basis that the right to operate telecom services had been acquired and the spectrum was put to use, and it deleted related enhancement and depreciation disallowance as a double adjustment. It also held that principal loan repayments were outside section 43B, removed additions based on inventory and internal reconciliation differences, upheld deletion of the DoT current account addition, and deleted section 14A disallowance because no exempt income was received. One TDS-related issue was remitted for verification.
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