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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Valuation report by registered valuer found flawed and unreliable. Adoption of rate without substantiation or comparable instances. Inconsistency in premium charged from promoters and investors for share allotment in same year. Registered valuer's report made to suit company's interest without corroborative evidence. Assessing Officer rightly calculated negative net worth due to continuous losses. Entire premium taxable as income from other sources. CIT(A)'s order set aside, Assessing Officer's order upheld. Revenue's appeal allowed.
Valuation report by registered valuer found flawed and unreliable. Adoption of rate without substantiation or comparable instances. Inconsistency in premium charged from promoters and investors for share allotment in same year. Registered valuer's report made to suit company's interest without corroborative evidence. Assessing Officer rightly calculated negative net worth due to continuous losses. Entire premium taxable as income from other sources. CIT(A)'s order set aside, Assessing Officer's order upheld. Revenue's appeal allowed.
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