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 addressed various issues including disallowance u/s 14A r.w.r.8D, where Revenue challenged deletion of disallowance made by AO. ITAT upheld CIT(A)'s decision, finding AO incorrectly treated expenses as direct, supporting Assessee's claim. CIT(A) correctly presumed investments made from interest-free funds. AO erred in not accepting Assessee's computation of disallowance, hence ITAT deleted disallowance u/s 14A. ITAT allowed Assessee's fresh claim for deduction u/s 37(1) for ERV loss, remanding for verification. ITAT upheld deduction of establishment expenses as revenue expenditure. ITAT dismissed Revenue's appeal on inclusion of ERV in inventory valuation. ITAT upheld CIT(A)'s order on Book Profits u/s 115JB and provision for Leave Encashment u/s 43B(f). ITAT supported Assessee's additional claim for ERV loss deduction, finding AO's rejection erroneous post accepting revised return.
The ITAT addressed various issues including disallowance u/s 14A r.w.r.8D, where Revenue challenged deletion of disallowance made by AO. ITAT upheld CIT(A)'s decision, finding AO incorrectly treated expenses as direct, supporting Assessee's claim. CIT(A) correctly presumed investments made from interest-free funds. AO erred in not accepting Assessee's computation of disallowance, hence ITAT deleted disallowance u/s 14A. ITAT allowed Assessee's fresh claim for deduction u/s 37(1) for ERV loss, remanding for verification. ITAT upheld deduction of establishment expenses as revenue expenditure. ITAT dismissed Revenue's appeal on inclusion of ERV in inventory valuation. ITAT upheld CIT(A)'s order on Book Profits u/s 115JB and provision for Leave Encashment u/s 43B(f). ITAT supported Assessee's additional claim for ERV loss deduction, finding AO's rejection erroneous post accepting revised return.
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