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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Retraction of statement given during survey - evidentiary value of statement recorded u/s 131 - Despite the retraction, the initial findings of the CIT(A) were largely upheld, as the tribunal found no concrete evidence supporting the assessee's claims of coercion, aside from the letter of retraction and an affidavit. The assessee was found to have unexplained excess cash and stock discrepancies. The Tribunal noted the lack of complete physical verification of stock during the survey but ultimately confirmed the addition, adjusting the gross profit rate applied from 10% to 8.02%, acknowledging some merit in the assessee's submissions regarding the survey’s conduct.
Retraction of statement given during survey - evidentiary value of statement recorded u/s 131 - Despite the retraction, the initial findings of the CIT(A) were largely upheld, as the tribunal found no concrete evidence supporting the assessee's claims of coercion, aside from the letter of retraction and an affidavit. The assessee was found to have unexplained excess cash and stock discrepancies. The Tribunal noted the lack of complete physical verification of stock during the survey but ultimately confirmed the addition, adjusting the gross profit rate applied from 10% to 8.02%, acknowledging some merit in the assessee's submissions regarding the survey’s conduct.
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