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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Excess work in progress detected during survey was accepted by assessee as income u/s 69B, taxable at 30%. Assessee claimed such income as part of closing stock to be allowed as deduction in next assessment year 2016-17. ITAT allowed assessee's claim, holding that income u/s 69B forms part of closing stock and can be claimed as deduction in next year, unlike Section 69C. Regarding deduction u/s 80IA for windmill units, ITAT followed CBDT Circular and its own earlier order treating each windmill as separate undertaking for Section 80IA deduction.
Excess work in progress detected during survey was accepted by assessee as income u/s 69B, taxable at 30%. Assessee claimed such income as part of closing stock to be allowed as deduction in next assessment year 2016-17. ITAT allowed assessee's claim, holding that income u/s 69B forms part of closing stock and can be claimed as deduction in next year, unlike Section 69C. Regarding deduction u/s 80IA for windmill units, ITAT followed CBDT Circular and its own earlier order treating each windmill as separate undertaking for Section 80IA deduction.
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