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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT deleted penalty for alleged under-reporting tied to the education cess claim. It held that the notice invoked a charge meant for processing under section 143(1)(a), while the case had been scrutinised under section 143(3) read with section 260, and no notice on the correct charge was issued. On merits, the deduction claim was supported by then-prevailing precedent; the later retrospective insertion of Explanation 3 to section 40(a)(ii) did not make it under-reporting, and section 155(18) was inapplicable because the claim had been disallowed, not allowed. The Tribunal also deleted the section 14A disallowance because no exempt income was earned and the 2022 amendment operated prospectively.
The ITAT deleted penalty for alleged under-reporting tied to the education cess claim. It held that the notice invoked a charge meant for processing under section 143(1)(a), while the case had been scrutinised under section 143(3) read with section 260, and no notice on the correct charge was issued. On merits, the deduction claim was supported by then-prevailing precedent; the later retrospective insertion of Explanation 3 to section 40(a)(ii) did not make it under-reporting, and section 155(18) was inapplicable because the claim had been disallowed, not allowed. The Tribunal also deleted the section 14A disallowance because no exempt income was earned and the 2022 amendment operated prospectively.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
