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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For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
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