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 ruled on various issues: 1. Compensation from RDG is business income u/s 28(ii)(c) & 28(va)(a). 2. Addition on flat sale cost is deleted as AO lacked power u/s 50A. 3. Disallowance of payments to PEL is deleted based on agreement terms. 4. Consultancy charges disallowance is pending review due to royalty decision. 5. Legal charges partly allowed, maintenance expenses to be verified. 6. Deduction u/s 35(2AB) requires Form 3CM approval. 7. Depreciation on R&D unit remitted back to AO. 8. Closing stock value to be re-evaluated. 9. Insurance claim remitted for actual loss verification. 10. Capital gain on RP House to be taxed over four years. 11. Rental income from RPIL House as income from house property. 12. Gain on sales tax deferral loan treated as capital receipt. 13. Deductions u/s 35A and 80HHC upheld for consistency. 14. Deduction u/s 80HHC for section 115JB based on adjusted book profit.
The ITAT ruled on various issues: 1. Compensation from RDG is business income u/s 28(ii)(c) & 28(va)(a). 2. Addition on flat sale cost is deleted as AO lacked power u/s 50A. 3. Disallowance of payments to PEL is deleted based on agreement terms. 4. Consultancy charges disallowance is pending review due to royalty decision. 5. Legal charges partly allowed, maintenance expenses to be verified. 6. Deduction u/s 35(2AB) requires Form 3CM approval. 7. Depreciation on R&D unit remitted back to AO. 8. Closing stock value to be re-evaluated. 9. Insurance claim remitted for actual loss verification. 10. Capital gain on RP House to be taxed over four years. 11. Rental income from RPIL House as income from house property. 12. Gain on sales tax deferral loan treated as capital receipt. 13. Deductions u/s 35A and 80HHC upheld for consistency. 14. Deduction u/s 80HHC for section 115JB based on adjusted book profit.
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