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 accordance with CBDT Instruction No. 3 of 2017, the AO exceeded jurisdiction by conducting inquiry into cash deposits up to Rs. 2.5 lakhs by an individual without business income. As per Source Specific General Verification Guidelines, no further verification is required for such cash deposits. The ITAT held that the AO erred by disregarding CBDT guidelines, which are binding, and relied on coordinate bench rulings granting exemption up to Rs. 2,50,000. Consequently, the assessee's appeal was allowed.
In accordance with CBDT Instruction No. 3 of 2017, the AO exceeded jurisdiction by conducting inquiry into cash deposits up to Rs. 2.5 lakhs by an individual without business income. As per Source Specific General Verification Guidelines, no further verification is required for such cash deposits. The ITAT held that the AO erred by disregarding CBDT guidelines, which are binding, and relied on coordinate bench rulings granting exemption up to Rs. 2,50,000. Consequently, the assessee's appeal was allowed.
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