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 applies even if books of account are not required to be maintained. Assessee failed to establish funds were duly reported and tax paid by husband. Addition u/s 56(2)(x)(b)(B) upheld as stamp duty paid exceeded thresholds, despite notice citing incorrect provision. Stamp duty leviable on market value, not guideline value. HC permitted assessee to file additional documents regarding source of funds, directed fresh order on 69A addition after providing opportunity of hearing. No interference on 56(2) addition. Costs imposed for non-cooperation.
Unexplained money u/s 69A applies even if books of account are not required to be maintained. Assessee failed to establish funds were duly reported and tax paid by husband. Addition u/s 56(2)(x)(b)(B) upheld as stamp duty paid exceeded thresholds, despite notice citing incorrect provision. Stamp duty leviable on market value, not guideline value. HC permitted assessee to file additional documents regarding source of funds, directed fresh order on 69A addition after providing opportunity of hearing. No interference on 56(2) addition. Costs imposed for non-cooperation.
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