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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Disallowances on account of non-payment of VAT before prescribed return filing date u/s 139(1) - assessee's submission of exclusive method of accounting without debiting VAT to profit and loss account rejected. Reliance on Ganapati Motors case distinguished as authorities had doubted and rejected assessee's accounting system, unlike in cited case. CIT(A) rightly discarded assessee's exclusive accounting method contrary to section 145A(ii) and Bombay High Court's decision in CIT vs. Knight Frank. Arguments incomprehensible due to factual differences from Ganapati Motors. No infirmity in CIT(A)'s confirmation of disallowance u/s 143(1). Partial deletion by CIT(A) of disallowance pertaining to earlier year upheld as settled law prohibits addition/disallowance of expenditure of different year in relevant year.
Disallowances on account of non-payment of VAT before prescribed return filing date u/s 139(1) - assessee's submission of exclusive method of accounting without debiting VAT to profit and loss account rejected. Reliance on Ganapati Motors case distinguished as authorities had doubted and rejected assessee's accounting system, unlike in cited case. CIT(A) rightly discarded assessee's exclusive accounting method contrary to section 145A(ii) and Bombay High Court's decision in CIT vs. Knight Frank. Arguments incomprehensible due to factual differences from Ganapati Motors. No infirmity in CIT(A)'s confirmation of disallowance u/s 143(1). Partial deletion by CIT(A) of disallowance pertaining to earlier year upheld as settled law prohibits addition/disallowance of expenditure of different year in relevant year.
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