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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Unexplained investment in land purchase - society's purchase in its name or trustees' names - CIT(A) considered money not paid by society from income but sourced from office bearers - AO held amount in sale deed is society's unexplained investment, not office bearers' undisclosed income. IBS noted society had no income for land purchase and no society reference in seized material. IBS accepted trustees' additional income utilized for society's land investment, trustees found with unaccounted money, not society. CIT(A) erred in observing no evidence of money flow from trustees when mobile data showed trustees' unaccounted money. Source investment can't be taxed again in society's hands after being taxed in trustees' hands. Non-submission of statements not controverted by department. No evidence of cash flow spent elsewhere, onus on AO to prove. Based on seized documents, trustees' unaccounted money paid for society's land can't be added to society's income. Ground allowed.
Unexplained investment in land purchase - society's purchase in its name or trustees' names - CIT(A) considered money not paid by society from income but sourced from office bearers - AO held amount in sale deed is society's unexplained investment, not office bearers' undisclosed income. IBS noted society had no income for land purchase and no society reference in seized material. IBS accepted trustees' additional income utilized for society's land investment, trustees found with unaccounted money, not society. CIT(A) erred in observing no evidence of money flow from trustees when mobile data showed trustees' unaccounted money. Source investment can't be taxed again in society's hands after being taxed in trustees' hands. Non-submission of statements not controverted by department. No evidence of cash flow spent elsewhere, onus on AO to prove. Based on seized documents, trustees' unaccounted money paid for society's land can't be added to society's income. Ground allowed.
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