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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The tribunal affirmed the decision of the CIT(A) to admit additional evidence under Rule 46A, leading to the deletion of disallowance on depreciation claims. Additionally, they upheld the deletion of addition on berth hire income, as it had already been accounted for by the assessee. Furthermore, the Tribunal dismissed the Revenue's appeal regarding the disallowance of depreciation claim for another assessment year, emphasizing the lack of sufficient basis for the ad-hoc disallowance on CSR expenses.
The tribunal affirmed the decision of the CIT(A) to admit additional evidence under Rule 46A, leading to the deletion of disallowance on depreciation claims. Additionally, they upheld the deletion of addition on berth hire income, as it had already been accounted for by the assessee. Furthermore, the Tribunal dismissed the Revenue's appeal regarding the disallowance of depreciation claim for another assessment year, emphasizing the lack of sufficient basis for the ad-hoc disallowance on CSR expenses.
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