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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Transfer pricing adjustment on quasi-equity transaction like non-convertible cumulative redeemable preference shares necessitates benchmarking cost with international LIBOR rates considering risk factors. Lease accounting principles differ for operating and finance leases; depreciation allowable on assets under finance lease. Employees' share option scheme expenses deductible subject to fulfillment of conditions. Disallowance u/s 14A restricted to investments yielding exempt income. Section 14A disallowance excluded from book profit computation u/s 115JB. Cash deposits during demonetization by authorized forex dealer requires substantiation. Depreciation allowable on property despite temporary letting if used for business. Indexation benefit available while computing book profit u/s 115JB.
Transfer pricing adjustment on quasi-equity transaction like non-convertible cumulative redeemable preference shares necessitates benchmarking cost with international LIBOR rates considering risk factors. Lease accounting principles differ for operating and finance leases; depreciation allowable on assets under finance lease. Employees' share option scheme expenses deductible subject to fulfillment of conditions. Disallowance u/s 14A restricted to investments yielding exempt income. Section 14A disallowance excluded from book profit computation u/s 115JB. Cash deposits during demonetization by authorized forex dealer requires substantiation. Depreciation allowable on property despite temporary letting if used for business. Indexation benefit available while computing book profit u/s 115JB.
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