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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Addition of excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The Tribunal observed that the assessee provided plausible explanations supported by evidence, including invoices, ledger accounts, bank statements, and acknowledgments from the parties. Despite this, the AO made the addition solely based on the partner's statement during the survey. However, the Tribunal found that the explanations provided by the assessee were credible and that there was no basis for the addition.
Addition of excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The Tribunal observed that the assessee provided plausible explanations supported by evidence, including invoices, ledger accounts, bank statements, and acknowledgments from the parties. Despite this, the AO made the addition solely based on the partner's statement during the survey. However, the Tribunal found that the explanations provided by the assessee were credible and that there was no basis for the addition.
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