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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Coffee hulling and curing charges incurred to process raw coffee beans into marketable coffee were held allowable as business expenditure under section 37(1) because the assessee produced ledger extracts, invoices and bank statements, and the work formed part of its regular business activity; the disallowance as unexplained expenditure was therefore deleted. The Tribunal also rejected the ad hoc 25% disallowance of agricultural expenses, noting supporting bills, vouchers, bank statements, cash details and regular books for diesel, fertiliser, pesticide, labour, transportation and related interest costs, with no specific unsupported item identified by the Revenue. The appeal was partly allowed and both disallowances were deleted.
Coffee hulling and curing charges incurred to process raw coffee beans into marketable coffee were held allowable as business expenditure under section 37(1) because the assessee produced ledger extracts, invoices and bank statements, and the work formed part of its regular business activity; the disallowance as unexplained expenditure was therefore deleted. The Tribunal also rejected the ad hoc 25% disallowance of agricultural expenses, noting supporting bills, vouchers, bank statements, cash details and regular books for diesel, fertiliser, pesticide, labour, transportation and related interest costs, with no specific unsupported item identified by the Revenue. The appeal was partly allowed and both disallowances were deleted.
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