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 foreign exchange fluctuation loss on sale proceeds held in the EEFC account - ITAT deleted addition - The High Court, after considering the arguments presented by both parties and referring to the Woodward Governor India case, concluded that the treatment of forex losses should adhere to the principles laid down in income tax law and accounting standards. It emphasized that such losses are considered as an item of expenditure under Section 37(1) of the Income Tax Act. As the issues raised had already been settled by precedent decisions, the Court declined to admit the appeal, affirming the decisions of the ITAT and the coordinate Bench of the Court.
Disallowance of foreign exchange fluctuation loss on sale proceeds held in the EEFC account - ITAT deleted addition - The High Court, after considering the arguments presented by both parties and referring to the Woodward Governor India case, concluded that the treatment of forex losses should adhere to the principles laid down in income tax law and accounting standards. It emphasized that such losses are considered as an item of expenditure under Section 37(1) of the Income Tax Act. As the issues raised had already been settled by precedent decisions, the Court declined to admit the appeal, affirming the decisions of the ITAT and the coordinate Bench of the Court.
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