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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT recalled its earlier order because it had decided an issue not arising from the Revenue's appeal, creating an apparent factual error. On rehearing, it held that unpaid service tax liability was not disallowable under section 43B where the assessee had not claimed any deduction and the amount had not been debited to the profit and loss account. Following the co-ordinate Bench ruling for another year, the Tribunal rejected the Revenue's challenge and dismissed the appeal.
The ITAT recalled its earlier order because it had decided an issue not arising from the Revenue's appeal, creating an apparent factual error. On rehearing, it held that unpaid service tax liability was not disallowable under section 43B where the assessee had not claimed any deduction and the amount had not been debited to the profit and loss account. Following the co-ordinate Bench ruling for another year, the Tribunal rejected the Revenue's challenge and dismissed the appeal.
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