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 several issues. Firstly, regarding the impact of pay revision of executives, it was held that the provision made by the assessee company for pay revision was justified, as the Delhi High Court's subsequent ruling supported the assessee's position. The provision of Rs. 17.65 crore was deemed necessary for the pay revision. Secondly, the non-grant of TDS credit due to income mismatch was dismissed as the issue had already been resolved by the assessing officer and CIT(A). Lastly, the amortization of deferred grant issue was sent back to the AO for re-verification and re-adjudication, as the AO had rejected the explanations without specific findings. Fairness and natural justice dictate that the issue be reconsidered with the opportunity for the assessee to be heard.
The Appellate Tribunal addressed several issues. Firstly, regarding the impact of pay revision of executives, it was held that the provision made by the assessee company for pay revision was justified, as the Delhi High Court's subsequent ruling supported the assessee's position. The provision of Rs. 17.65 crore was deemed necessary for the pay revision. Secondly, the non-grant of TDS credit due to income mismatch was dismissed as the issue had already been resolved by the assessing officer and CIT(A). Lastly, the amortization of deferred grant issue was sent back to the AO for re-verification and re-adjudication, as the AO had rejected the explanations without specific findings. Fairness and natural justice dictate that the issue be reconsidered with the opportunity for the assessee to be heard.
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