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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Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
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