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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Denial of 80P(2)(a)(i) deduction - interest income - The Tribunal acknowledged the appellant's argument that the interest earned on deposits from a reserve fund constituted business income derived from providing credit facilities to members, thus qualifying for deductions u/s80P(2)(a)(i). - However, following precedent set by the Hon'ble Karnataka High Court and various other rulings, the Tribunal ruled that interest income from deposits held in banks does not change its nature as income from other sources, regardless of the entity type from which the interest is received. The Tribunal also directed the assessing officer to consider the proportionate costs and administrative expenses incurred in generating the interest income, thereby allowing a partial relief to the assessee.
Denial of 80P(2)(a)(i) deduction - interest income - The Tribunal acknowledged the appellant's argument that the interest earned on deposits from a reserve fund constituted business income derived from providing credit facilities to members, thus qualifying for deductions u/s80P(2)(a)(i). - However, following precedent set by the Hon'ble Karnataka High Court and various other rulings, the Tribunal ruled that interest income from deposits held in banks does not change its nature as income from other sources, regardless of the entity type from which the interest is received. The Tribunal also directed the assessing officer to consider the proportionate costs and administrative expenses incurred in generating the interest income, thereby allowing a partial relief to the assessee.
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