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 money u/s 69A read with Section 115BBE(1) - no explanation regarding source of cash deposit in savings account - case selected for limited scrutiny, thus recharacterization of income as unexplained u/s 69A beyond scope of limited scrutiny, liable to be struck down. Scope of limited scrutiny upheld for verifying demonetization cash deposits. Cash deposits in November 2016 governed by pre-amended Section 115BBE. Assessee failed to explain nature and source of cash deposit, rightly treated as unexplained money u/s 69A. Income disclosed under "income from other sources" cannot be treated as explained source for cash deposit. Tax rightly levied at 60% u/s 115BBE(1) on unexplained money. Appeal dismissed.
Unexplained money u/s 69A read with Section 115BBE(1) - no explanation regarding source of cash deposit in savings account - case selected for limited scrutiny, thus recharacterization of income as unexplained u/s 69A beyond scope of limited scrutiny, liable to be struck down. Scope of limited scrutiny upheld for verifying demonetization cash deposits. Cash deposits in November 2016 governed by pre-amended Section 115BBE. Assessee failed to explain nature and source of cash deposit, rightly treated as unexplained money u/s 69A. Income disclosed under "income from other sources" cannot be treated as explained source for cash deposit. Tax rightly levied at 60% u/s 115BBE(1) on unexplained money. Appeal dismissed.
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