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 interest u/s 36(1)(iii) - The AO had disallowed the interest claimed by the assessee on advances made to its Director, citing a lack of nexus between the advances and the business activities of the assessee. The assessee contended that the advances were made for business purposes and out of commercial expediency. - The Appellate Tribunal recognized the importance of establishing a clear nexus between the advances and the business activities of the assessee. It also emphasized the need to verify the availability of interest-free funds with the assessee at the time of advancing the loan. - The ITAT ordered the AO to examine the additional evidence provided by the assessee and provide an opportunity for the assessee to substantiate its case.
Disallowance of interest u/s 36(1)(iii) - The AO had disallowed the interest claimed by the assessee on advances made to its Director, citing a lack of nexus between the advances and the business activities of the assessee. The assessee contended that the advances were made for business purposes and out of commercial expediency. - The Appellate Tribunal recognized the importance of establishing a clear nexus between the advances and the business activities of the assessee. It also emphasized the need to verify the availability of interest-free funds with the assessee at the time of advancing the loan. - The ITAT ordered the AO to examine the additional evidence provided by the assessee and provide an opportunity for the assessee to substantiate its case.
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