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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Undisclosed commission income - To be taxed as accommodation entry or only commission income on such transactions - The assessee cannot blow hot and cold at the same time and assert that the sum identified by the Investigating authorities be treated as tainted and the rest of the transactions be accepted at its face value to be sacrosanct. - AT
Undisclosed commission income - To be taxed as accommodation entry or only commission income on such transactions - The assessee cannot blow hot and cold at the same time and assert that the sum identified by the Investigating authorities be treated as tainted and the rest of the transactions be accepted at its face value to be sacrosanct. - AT
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