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Income Tax : ITAT Mumbai held that prolonged non-payment of interest and repeated amendments to loan agreements justified benchmarking AE loans...
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The Ahmedabad ITAT held that goodwill arising from a High Court-approved amalgamation qualified as an intangible asset eligible for depreciation under Section 32(1)(ii). The Tribunal followed earlier decisions in the assessee’s own case.
Calcutta High Court held that failure to investigate allocation of common head office expenses to eligible units rendered assessment erroneous and prejudicial to Revenue interests.
The ITAT Delhi ruled that reimbursement of software costs to foreign AEs on a cost-to-cost basis could not be treated as a profit-generating intra-group service. The Tribunal deleted the transfer pricing adjustment after finding the benchmarking method adopted by the TPO unjustified.
ITAT ruled that deduction under Section 80JJAA could not be claimed where the business was acquired through amalgamation. The Tribunal held that transfer of assets, liabilities, and business operations constituted business reorganisation under the Act.
ITAT Mumbai held that prolonged non-payment of interest and repeated amendments to loan agreements justified benchmarking AE loans at a fixed 6.5% rate instead of floating LIBOR rates. The Tribunal also directed grant of credit for interest income already offered to tax suo motu.
The Tribunal found that the transfer pricing adjustment was incorrectly computed using SEB sale rates. It allowed deduction based on consumer tariff rates. The decision clarifies benchmarking for captive consumption.
The Tribunal held that industrial tariff charged by electricity boards is the correct benchmark for CPP transactions. It rejected the use of generator procurement rates adopted by the TPO.
The issue concerned overlap of deductions under Sections 80-IA and 80HHC. The Court held that 80HHC profits cannot be reduced by 80-IA deduction, ensuring independent computation.
The court held that electricity tariff for determining market value must include all components, including duty. It ruled that excluding such elements artificially reduces eligible deduction.
Consistency over technicalities: ITAT Mumbai allowed actuarial pension provision as an ascertained liability, rejected mechanical disallowances, and held CBDT instructions cannot override the Income-tax Act.
