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 obtained loan from bogus entry provider but failed to produce lender despite directions. Inquiry prevented by assessee. Unusual for lender providing huge loans yearly without being produced. Assessee duty-bound to explain creditor identity, transaction genuineness, creditor creditworthiness. AO asked source of credit, not source of source. Appeal restored to AO to examine by producing company directors. No cross-examination requirement as assessee must independently prove cash credit ingredients. AO to examine transactions per Section 68 parameters, not relying on confessions/retractions. Appeal allowed statistically.
Assessee obtained loan from bogus entry provider but failed to produce lender despite directions. Inquiry prevented by assessee. Unusual for lender providing huge loans yearly without being produced. Assessee duty-bound to explain creditor identity, transaction genuineness, creditor creditworthiness. AO asked source of credit, not source of source. Appeal restored to AO to examine by producing company directors. No cross-examination requirement as assessee must independently prove cash credit ingredients. AO to examine transactions per Section 68 parameters, not relying on confessions/retractions. Appeal allowed statistically.
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