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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Set off of loss against income referred to in section 68 r/w.s115BBE - The tribunal agreed with the arguments of the assessee, emphasizing that the amendments in section 115BBE are effective from AY 2017-18. Hence, for AYs 2011-12 and 2015-16, the assessee is entitled to claim the set-off of business loss against income u/s 68. The tribunal cited the CBDT Circular No. 11/2019 and the Kerala High Court’s decision, both supporting the assessee's position.
Set off of loss against income referred to in section 68 r/w.s115BBE - The tribunal agreed with the arguments of the assessee, emphasizing that the amendments in section 115BBE are effective from AY 2017-18. Hence, for AYs 2011-12 and 2015-16, the assessee is entitled to claim the set-off of business loss against income u/s 68. The tribunal cited the CBDT Circular No. 11/2019 and the Kerala High Court’s decision, both supporting the assessee's position.
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