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 multiple issues related to the assessee's eligibility for deduction u/s 80IA and various additions made by the AO. The AO's assessment u/s 153A questioned the deduction u/s 80IA, but the ITAT upheld the assessee's claim, noting no incriminating material was found during the search. The ITAT also addressed alleged illegal payments, finding no corroborative evidence to support the claims. Additions u/s 68 related to share capital were dismissed as the transactions were independent of the assessee's involvement. Additional issues such as unrecorded cash transactions, subcontract payments, sale of Gitti, and other unaccounted transactions were also dismissed due to lack of corroborative evidence and retracted statements. The ITAT affirmed the CIT(A)'s decisions, granting relief to the assessee on all contested grounds.
The ITAT addressed multiple issues related to the assessee's eligibility for deduction u/s 80IA and various additions made by the AO. The AO's assessment u/s 153A questioned the deduction u/s 80IA, but the ITAT upheld the assessee's claim, noting no incriminating material was found during the search. The ITAT also addressed alleged illegal payments, finding no corroborative evidence to support the claims. Additions u/s 68 related to share capital were dismissed as the transactions were independent of the assessee's involvement. Additional issues such as unrecorded cash transactions, subcontract payments, sale of Gitti, and other unaccounted transactions were also dismissed due to lack of corroborative evidence and retracted statements. The ITAT affirmed the CIT(A)'s decisions, granting relief to the assessee on all contested grounds.
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