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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Unverified sundry creditors may be examined as unexplained credits; their classification alone does not preclude an addition. Business-expenditure disallowances cannot be substantially reduced without evidence substantiating the expenditure. Appellate relief deleting the creditor addition and reducing the expenditure disallowance was set aside because the assessee sought to produce evidence for the accounting entries and its tax-exemption claim. The additions and exemption claim were remitted to the Assessing Officer for fresh factual consideration on the evidence, without a decision on merits.
Unverified sundry creditors may be examined as unexplained credits; their classification alone does not preclude an addition. Business-expenditure disallowances cannot be substantially reduced without evidence substantiating the expenditure. Appellate relief deleting the creditor addition and reducing the expenditure disallowance was set aside because the assessee sought to produce evidence for the accounting entries and its tax-exemption claim. The additions and exemption claim were remitted to the Assessing Officer for fresh factual consideration on the evidence, without a decision on merits.
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