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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Provision of section 145(3) invoked without satisfying conditions - books of accounts rejected without following proper procedure u/s 144. Gross profit addition made instead of excess stock found, ignoring documentary evidence. Statement alone cannot be basis for addition as per apex court ruling. Excess stock forming part of closing stock demonstrated through CA certificate, hence no separate addition required. Bogus expenses declared during survey were from assessee's own cash available, not requiring cash flow statement. Grounds raised by assessee allowed by ITAT.
Provision of section 145(3) invoked without satisfying conditions - books of accounts rejected without following proper procedure u/s 144. Gross profit addition made instead of excess stock found, ignoring documentary evidence. Statement alone cannot be basis for addition as per apex court ruling. Excess stock forming part of closing stock demonstrated through CA certificate, hence no separate addition required. Bogus expenses declared during survey were from assessee's own cash available, not requiring cash flow statement. Grounds raised by assessee allowed by ITAT.
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