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(4)(i) on storage tank MDI and storage tank EDA - By affirming the eligibility for deductions u/s 80IA(4) for the specialized storage tanks, the tribunal underscored the broader interpretation of infrastructure facilities in the context of port operations. The decision to allow share issue expenses under section 35D reiterates the acceptance of capital nature expenses pre-business commencement. Meanwhile, the nuanced approach in dealing with section 14A disallowances reflects the tribunal's acknowledgment of the complexity surrounding the allocation of expenses towards earning exempt income.
Deduction u/s. 80IA(4)(i) on storage tank MDI and storage tank EDA - By affirming the eligibility for deductions u/s 80IA(4) for the specialized storage tanks, the tribunal underscored the broader interpretation of infrastructure facilities in the context of port operations. The decision to allow share issue expenses under section 35D reiterates the acceptance of capital nature expenses pre-business commencement. Meanwhile, the nuanced approach in dealing with section 14A disallowances reflects the tribunal's acknowledgment of the complexity surrounding the allocation of expenses towards earning exempt income.
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