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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Tribunal adjudicated on ad hoc disallowances of expenses debited to P&L, interest paid to banks, salary from Ozone Pharmaceuticals Ltd., deduction u/s 80IB/80IC, and disallowance of selling/distribution expenses. Disallowances were deleted as unsustainable without adverse material. Interest disallowance deleted as borrowed funds utilized for working capital. Salary disallowance deleted as no salary received. Deduction u/s 80IC allowed as conditions satisfied. Selling/distribution expenses disallowance restricted to 10% instead of 25%. Tribunal decided in favor of assessee against revenue on various grounds.
Tribunal adjudicated on ad hoc disallowances of expenses debited to P&L, interest paid to banks, salary from Ozone Pharmaceuticals Ltd., deduction u/s 80IB/80IC, and disallowance of selling/distribution expenses. Disallowances were deleted as unsustainable without adverse material. Interest disallowance deleted as borrowed funds utilized for working capital. Salary disallowance deleted as no salary received. Deduction u/s 80IC allowed as conditions satisfied. Selling/distribution expenses disallowance restricted to 10% instead of 25%. Tribunal decided in favor of assessee against revenue on various grounds.
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