Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Intra-group technical and IT services are priced using a 10% cost mark-up, after crediting recoveries, because Safe Harbour margins did not apply for the relevant year. Actuarially measured pension and other employee-benefit liabilities arising from past service are accrued liabilities, while privilege-leave encashment remains deductible only on actual payment. Exempt-income expenditure requires limited recomputation excluding interest, considering only income-yielding investments, and capped at exempt income. Banking securities may be valued under a consistently followed recognised method reflecting real income; interest on non-performing advances or investments is not taxed where recovery is uncertain under prudential norms. Bad-debt provisions, recovery taxation, and deductions for non-rural write-offs require statutory-limit, prior-deduction, and factual verification. Foreign branch income remains included in Indian total income, subject to double-tax relief.
Intra-group technical and IT services are priced using a 10% cost mark-up, after crediting recoveries, because Safe Harbour margins did not apply for the relevant year. Actuarially measured pension and other employee-benefit liabilities arising from past service are accrued liabilities, while privilege-leave encashment remains deductible only on actual payment. Exempt-income expenditure requires limited recomputation excluding interest, considering only income-yielding investments, and capped at exempt income. Banking securities may be valued under a consistently followed recognised method reflecting real income; interest on non-performing advances or investments is not taxed where recovery is uncertain under prudential norms. Bad-debt provisions, recovery taxation, and deductions for non-rural write-offs require statutory-limit, prior-deduction, and factual verification. Foreign branch income remains included in Indian total income, subject to double-tax relief.
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