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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Disallowance of interest u/s 36(1)(iii) - Advance given to Individual for purchase of property - The CIT(A) found that the advance was for purchasing a property intended for business use, as the property had been on lease to the assessee since 2007 and continued to be used as the corporate office. The Tribunal upheld the CIT(A)'s decision, noting that the Department could not present new evidence to counter the CIT(A)'s findings. The disallowance was deemed incorrect as the advance was eventually recovered, demonstrating its business nature.
Disallowance of interest u/s 36(1)(iii) - Advance given to Individual for purchase of property - The CIT(A) found that the advance was for purchasing a property intended for business use, as the property had been on lease to the assessee since 2007 and continued to be used as the corporate office. The Tribunal upheld the CIT(A)'s decision, noting that the Department could not present new evidence to counter the CIT(A)'s findings. The disallowance was deemed incorrect as the advance was eventually recovered, demonstrating its business nature.
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