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 Appellate Tribunal addressed a case involving revision u/s 263 by PCIT questioning the recognition of liabilities 'Nardana Claim-1' and 'Nardana Claim-2' under ICDS. The Tribunal found that AO adequately investigated the issues through queries and responses from the assessee, rejecting PCIT's claim of lack of investigation. The Tribunal upheld the assessee's explanation that the liabilities were not recognized as income due to pending court disputes, following a court decision on income accrual. Citing Malabar Industries Co. Ltd., the Tribunal held that AO's view favoring the assessee was valid. PCIT's revision based on ICDS violations was deemed unsustainable, leading to the quashing of the revision order and restoration of the AO's assessment order. Assessee's appeal was allowed.
The Appellate Tribunal addressed a case involving revision u/s 263 by PCIT questioning the recognition of liabilities 'Nardana Claim-1' and 'Nardana Claim-2' under ICDS. The Tribunal found that AO adequately investigated the issues through queries and responses from the assessee, rejecting PCIT's claim of lack of investigation. The Tribunal upheld the assessee's explanation that the liabilities were not recognized as income due to pending court disputes, following a court decision on income accrual. Citing Malabar Industries Co. Ltd., the Tribunal held that AO's view favoring the assessee was valid. PCIT's revision based on ICDS violations was deemed unsustainable, leading to the quashing of the revision order and restoration of the AO's assessment order. Assessee's appeal was allowed.
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