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 case involves determining the correct head of income u/s 69 and 115BB for an assessee family engaged in money lending business. The ITAT held that the undisclosed income from sundry debtors should be treated as 'business income' due to the nature of the money lending business. The lack of proper accounting records was considered, and the undisclosed income was deemed to be ploughed back into the business. The ITAT directed the AO to re-compute the income accordingly. Additionally, a dispute u/s 56(2)(vii)(b) regarding property purchase was raised, and the ITAT directed the CIT(A) to consider the issue on merits.
The case involves determining the correct head of income u/s 69 and 115BB for an assessee family engaged in money lending business. The ITAT held that the undisclosed income from sundry debtors should be treated as 'business income' due to the nature of the money lending business. The lack of proper accounting records was considered, and the undisclosed income was deemed to be ploughed back into the business. The ITAT directed the AO to re-compute the income accordingly. Additionally, a dispute u/s 56(2)(vii)(b) regarding property purchase was raised, and the ITAT directed the CIT(A) to consider the issue on merits.
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