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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Whether the paper company is engaged in any tax evasion? - Income Tax Act has been amended by incorporating the provisions of PoEM, GAAR for bringing such transactions under the net of tax. However, the provisions are not applicable to the year under consideration. Therefore, we are of the view that until and unless there is any violation of the provisions of law, it cannot be alleged that the assessee by adopting the colourable device has diverted the profit. - As we have decided the issue that profit attributable to RFZC belongs to DRC companies, then the question of the colourable device used by the assessee for diverting its profit does not arise. - AT
Whether the paper company is engaged in any tax evasion? - Income Tax Act has been amended by incorporating the provisions of PoEM, GAAR for bringing such transactions under the net of tax. However, the provisions are not applicable to the year under consideration. Therefore, we are of the view that until and unless there is any violation of the provisions of law, it cannot be alleged that the assessee by adopting the colourable device has diverted the profit. - As we have decided the issue that profit attributable to RFZC belongs to DRC companies, then the question of the colourable device used by the assessee for diverting its profit does not arise. - AT
Note: It is a system-generated summary and is for quick reference only.