Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Additions for alleged unaccounted admission fees based on seized loose sheets, visitors' slips and diary entries require adequate corroboration. Material relating to specific years cannot support extrapolated additions for other years, and estimated suppression of fees for remaining seats cannot rest on unsupported assumptions. For cancellation seats, an assumption of management-quota fee collection was unsupported where admissions were governed by an agreement restricting fees and admission records were produced. The HC upheld deletion of the additions, finding that the Revenue had not shown perversity in the Tribunal's factual findings. Under section 260A, the HC cannot reappreciate evidence or substitute factual conclusions absent findings based on no evidence or perversity. Exemption issues were left open.
Additions for alleged unaccounted admission fees based on seized loose sheets, visitors' slips and diary entries require adequate corroboration. Material relating to specific years cannot support extrapolated additions for other years, and estimated suppression of fees for remaining seats cannot rest on unsupported assumptions. For cancellation seats, an assumption of management-quota fee collection was unsupported where admissions were governed by an agreement restricting fees and admission records were produced. The HC upheld deletion of the additions, finding that the Revenue had not shown perversity in the Tribunal's factual findings. Under section 260A, the HC cannot reappreciate evidence or substitute factual conclusions absent findings based on no evidence or perversity. Exemption issues were left open.
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