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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Interest paid for delayed licence or migration fee for radio channels was treated as revenue expenditure because the stations were already operational and the payment was compensatory, not for creating a new asset. A section 14A disallowance was deleted because no exempt income was earned from the relevant investments. CSR donation paid to an approved section 80G fund was held deductible, as CSR disallowance under section 37(1) did not bar the claim and any ambiguity in the taxing provision had to be resolved in favour of the assessee. Depreciation was allowed on workforce-related intangible rights acquired under a slump sale, as the employees formed part of the going concern and the amalgamation proviso was inapplicable.
Interest paid for delayed licence or migration fee for radio channels was treated as revenue expenditure because the stations were already operational and the payment was compensatory, not for creating a new asset. A section 14A disallowance was deleted because no exempt income was earned from the relevant investments. CSR donation paid to an approved section 80G fund was held deductible, as CSR disallowance under section 37(1) did not bar the claim and any ambiguity in the taxing provision had to be resolved in favour of the assessee. Depreciation was allowed on workforce-related intangible rights acquired under a slump sale, as the employees formed part of the going concern and the amalgamation proviso was inapplicable.
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