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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Revision u/s 263 - Additions u/s 69 r.w.s. 115BBE - excess stock found during the course of survey as admitted to be the undisclosed business income of the assessee, by the main partner in the assessee firm - The ITAT found that since the department did not find other sources of income during the survey, it was reasonable to treat the excess stock as business income. Therefore, the AO's decision was not erroneous, and the invocation of revision powers under Section 263 - The Tribunal observed that the excess stock was not separately identifiable and was part of a mixed lot found during the survey. Considering precedents and the nature of the excess stock, it was deemed to be the business income of the assessee. Therefore, the AO's decision to tax it as business income was upheld.
Revision u/s 263 - Additions u/s 69 r.w.s. 115BBE - excess stock found during the course of survey as admitted to be the undisclosed business income of the assessee, by the main partner in the assessee firm - The ITAT found that since the department did not find other sources of income during the survey, it was reasonable to treat the excess stock as business income. Therefore, the AO's decision was not erroneous, and the invocation of revision powers under Section 263 - The Tribunal observed that the excess stock was not separately identifiable and was part of a mixed lot found during the survey. Considering precedents and the nature of the excess stock, it was deemed to be the business income of the assessee. Therefore, the AO's decision to tax it as business income was upheld.
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