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 cash deposits u/s 68 - abnormal sales reported by the assessee during demonetized period - The Tribunal found no merit in the Revenue's argument that the sales were abnormal, highlighting that no concrete evidence was presented to substantiate the claim of unaccounted money being introduced as sales. Furthermore, the Tribunal noted the impossibility of producing CCTV footage as demanded by the Revenue, years after the transactions took place. Based on the thorough documentation provided by the assessee, the Tribunal ruled that the cash deposits were sourced from legitimate sales proceeds.
Addition of cash deposits u/s 68 - abnormal sales reported by the assessee during demonetized period - The Tribunal found no merit in the Revenue's argument that the sales were abnormal, highlighting that no concrete evidence was presented to substantiate the claim of unaccounted money being introduced as sales. Furthermore, the Tribunal noted the impossibility of producing CCTV footage as demanded by the Revenue, years after the transactions took place. Based on the thorough documentation provided by the assessee, the Tribunal ruled that the cash deposits were sourced from legitimate sales proceeds.
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