Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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The ITAT upheld deletion of transfer pricing adjustments on captive power supplied to eligible manufacturing units for section 80-IA purposes, applying the Supreme Court principle that the relevant market value is the rate charged by the State Electricity Board or distribution company to industrial consumers, not the regulated or contracted surplus-power rate. It accepted the annual landed cost paid by the manufacturing units as the proper benchmark and rejected the Revenue's challenge. The Tribunal also sustained allocation of common head office expenses on the fixed-asset ratio, holding that the Revenue had followed the same method in earlier years and no change in facts or law justified a profitability-based allocation. All four Revenue appeals were dismissed.
The ITAT upheld deletion of transfer pricing adjustments on captive power supplied to eligible manufacturing units for section 80-IA purposes, applying the Supreme Court principle that the relevant market value is the rate charged by the State Electricity Board or distribution company to industrial consumers, not the regulated or contracted surplus-power rate. It accepted the annual landed cost paid by the manufacturing units as the proper benchmark and rejected the Revenue's challenge. The Tribunal also sustained allocation of common head office expenses on the fixed-asset ratio, holding that the Revenue had followed the same method in earlier years and no change in facts or law justified a profitability-based allocation. All four Revenue appeals were dismissed.
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