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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Deduction u/s 80IA - profit of Generation of electricity - notional income from savings in Low Sulphur Heavy Stock (LSHS) due to steam generation by the assessee's captive power plant. - The tribunal emphasized that the assessee had fully disclosed the computation of profits, including the method of valuing steam generation, which constituted an integral part of the income from the industrial undertaking. The ITAT thus upheld the assessee's claim, affirming that notional income from steam generation could be considered for deductions under Section 80IA.
Deduction u/s 80IA - profit of Generation of electricity - notional income from savings in Low Sulphur Heavy Stock (LSHS) due to steam generation by the assessee's captive power plant. - The tribunal emphasized that the assessee had fully disclosed the computation of profits, including the method of valuing steam generation, which constituted an integral part of the income from the industrial undertaking. The ITAT thus upheld the assessee's claim, affirming that notional income from steam generation could be considered for deductions under Section 80IA.
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