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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Deduction for additional employee cost could not be denied merely because Form No. 10DA was uploaded after the due date, where the assessee had obtained the form in time, attempted upload before the deadline, and the delay arose from technical glitches in the e-filing portal. The form was already on record before the return of income was filed and was available when the return was processed, so the Tribunal followed co-ordinate Bench rulings and directed the Assessing Officer to admit the form and allow the deduction in accordance with law. The Department's objection based on a later rejection under section 119(2)(b) was not accepted.
Deduction for additional employee cost could not be denied merely because Form No. 10DA was uploaded after the due date, where the assessee had obtained the form in time, attempted upload before the deadline, and the delay arose from technical glitches in the e-filing portal. The form was already on record before the return of income was filed and was available when the return was processed, so the Tribunal followed co-ordinate Bench rulings and directed the Assessing Officer to admit the form and allow the deduction in accordance with law. The Department's objection based on a later rejection under section 119(2)(b) was not accepted.
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