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 ITAT Indore addressed various issues in the case. Firstly, it ruled that interest on outstanding GST is allowable as a business expenditure, not a penalty, and cannot be disallowed u/s 37(1). Secondly, interest on belated TDS deposit is not an allowable business deduction, akin to income tax liabilities, and was rightly disallowed. Thirdly, adhoc disallowance of traveling expenses by AO was unfounded as no personal element was proven, leading to deletion of the disallowance by CIT(A). The appeal was partly allowed in favor of the assessee.
The ITAT Indore addressed various issues in the case. Firstly, it ruled that interest on outstanding GST is allowable as a business expenditure, not a penalty, and cannot be disallowed u/s 37(1). Secondly, interest on belated TDS deposit is not an allowable business deduction, akin to income tax liabilities, and was rightly disallowed. Thirdly, adhoc disallowance of traveling expenses by AO was unfounded as no personal element was proven, leading to deletion of the disallowance by CIT(A). The appeal was partly allowed in favor of the assessee.
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