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 deduction claimed under Chapter VI-A i.e. Section 80G/ 80GGA read with Section 35AC - The Appellate Tribunal noted that the appellant had not claimed the benefit of Sections 11 and 12 of the Act, as reflected in the AO's intimation order under Section 143(1) of the Act. Therefore, the appellant was entitled to deduction under Section 80GGA of the Act. Considering the appellant's consistent claims for deduction under Section 80GGA since Assessment Year 1993-94, and the absence of contrary evidence presented by the Revenue, the Tribunal upheld the appellant's entitlement to the deduction.
Denial of deduction claimed under Chapter VI-A i.e. Section 80G/ 80GGA read with Section 35AC - The Appellate Tribunal noted that the appellant had not claimed the benefit of Sections 11 and 12 of the Act, as reflected in the AO's intimation order under Section 143(1) of the Act. Therefore, the appellant was entitled to deduction under Section 80GGA of the Act. Considering the appellant's consistent claims for deduction under Section 80GGA since Assessment Year 1993-94, and the absence of contrary evidence presented by the Revenue, the Tribunal upheld the appellant's entitlement to the deduction.
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