Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Accrual of income - Reimbursement of expenses treated as income of the Assessee - Application of Markup on Reimbursement Expenses: The contentious issue was whether the Assessee should apply a markup on these reimbursement expenses. The Commissioner had directed a 13% markup, a decision that was challenged. The Tribunal remanded this issue back to the Commissioner for a detailed examination of whether the Assessee's role was merely as a conduit or if it played a significant role that could justify the markup.
Accrual of income - Reimbursement of expenses treated as income of the Assessee - Application of Markup on Reimbursement Expenses: The contentious issue was whether the Assessee should apply a markup on these reimbursement expenses. The Commissioner had directed a 13% markup, a decision that was challenged. The Tribunal remanded this issue back to the Commissioner for a detailed examination of whether the Assessee's role was merely as a conduit or if it played a significant role that could justify the markup.
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