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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Input Tax Credit (ITC) - bunds/ crystallizer which are constructed and used in the manufacture of salt and bromine chemicals - bunds/ crystallizer can be said to be covered under ‘any other civil structures’ - When the exclusion clause (i) excludes ‘land, building or any other civil structures’ from the purview of the definition of ‘plant and machinery’, the phrase ‘any other civil structures’ naturally refers to all other civil structures, other than foundation and structural supports used to fix the apparatus, equipment, and machinery to earth. - AAAR
Input Tax Credit (ITC) - bunds/ crystallizer which are constructed and used in the manufacture of salt and bromine chemicals - bunds/ crystallizer can be said to be covered under ‘any other civil structures’ - When the exclusion clause (i) excludes ‘land, building or any other civil structures’ from the purview of the definition of ‘plant and machinery’, the phrase ‘any other civil structures’ naturally refers to all other civil structures, other than foundation and structural supports used to fix the apparatus, equipment, and machinery to earth. - AAAR
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