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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Disallowance of brokerage paid to various persons by considering them to be ingenuine - When the Department has accepted the Income Tax Returns of the brokers and did not find any infirmity then it is not imperative by the AO to compel the lady brokers for verification whose details have already been provided by the ld. AR of the assessee as per the format of the AO. - Additions deleted - AT
Disallowance of brokerage paid to various persons by considering them to be ingenuine - When the Department has accepted the Income Tax Returns of the brokers and did not find any infirmity then it is not imperative by the AO to compel the lady brokers for verification whose details have already been provided by the ld. AR of the assessee as per the format of the AO. - Additions deleted - AT
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