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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Assessee surrendered income during survey u/s 133A as unaccounted professional receipts, which AO accepted as professional income taxable at normal rates. PCIT invoked revision u/s 263, alleging AO didn't inquire about surrendered income's nature. ITAT held PCIT's finding unsustainable as AO conducted due inquiry, assessee voluntarily surrendered professional receipts, disclosed and audited them, and AO's acceptance accorded with judicial precedents. PCIT didn't examine survey records to substantiate error, merely stating AO didn't inquire without evidence. ITAT ruled PCIT lacked valid jurisdiction for revision.
Assessee surrendered income during survey u/s 133A as unaccounted professional receipts, which AO accepted as professional income taxable at normal rates. PCIT invoked revision u/s 263, alleging AO didn't inquire about surrendered income's nature. ITAT held PCIT's finding unsustainable as AO conducted due inquiry, assessee voluntarily surrendered professional receipts, disclosed and audited them, and AO's acceptance accorded with judicial precedents. PCIT didn't examine survey records to substantiate error, merely stating AO didn't inquire without evidence. ITAT ruled PCIT lacked valid jurisdiction for revision.
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