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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In a recent High Court case, the issue of whether advertisement expenditure could be considered as allowable revenue expenditure was discussed. The ITAT allowed the claim, citing a previous decision where the Tribunal's judgment was accepted by the Revenue. The Court agreed with the assessee, stating that the Revenue cannot raise a question of law if it had accepted the Tribunal's finding in a previous year. Regarding Voluntary Retirement Scheme (VRS) payments, the Court followed a previous decision in favor of the assessee. Advances for Project Development were also treated as revenue expenses. Expenses related to workmen and staff welfare were allowed u/s 40A(9), following the principles established in a Supreme Court case. The Court upheld the Tribunal's decision in the assessee's favor based on consistency with a previous year's ruling.
In a recent High Court case, the issue of whether advertisement expenditure could be considered as allowable revenue expenditure was discussed. The ITAT allowed the claim, citing a previous decision where the Tribunal's judgment was accepted by the Revenue. The Court agreed with the assessee, stating that the Revenue cannot raise a question of law if it had accepted the Tribunal's finding in a previous year. Regarding Voluntary Retirement Scheme (VRS) payments, the Court followed a previous decision in favor of the assessee. Advances for Project Development were also treated as revenue expenses. Expenses related to workmen and staff welfare were allowed u/s 40A(9), following the principles established in a Supreme Court case. The Court upheld the Tribunal's decision in the assessee's favor based on consistency with a previous year's ruling.
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