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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Expenditure on power, fuel, and lease rent for hired machines held as capital expenditure incurred for establishing cement manufacturing unit at Bilaspur by ITAT, contrary to CIT(A) treating it as revenue expenditure. HC observed Revenue unable to state if appeal filed against Tribunal's order for AY 1984-85 on same issue. Principle of consistency applied based on Tribunal's order for AY 1984-85 in M/s. Raymond Woollen Mills Ltd. and HC orders for subsequent AYs. Referred Supreme Court's rulings in Godrej and Boyce Manufacturing Company Ltd. and Radhasoami Satsang reiterating need for consistency, certainty, and strong reasons for departure from settled position, which was absent. Assessee's appeal allowed.
Expenditure on power, fuel, and lease rent for hired machines held as capital expenditure incurred for establishing cement manufacturing unit at Bilaspur by ITAT, contrary to CIT(A) treating it as revenue expenditure. HC observed Revenue unable to state if appeal filed against Tribunal's order for AY 1984-85 on same issue. Principle of consistency applied based on Tribunal's order for AY 1984-85 in M/s. Raymond Woollen Mills Ltd. and HC orders for subsequent AYs. Referred Supreme Court's rulings in Godrej and Boyce Manufacturing Company Ltd. and Radhasoami Satsang reiterating need for consistency, certainty, and strong reasons for departure from settled position, which was absent. Assessee's appeal allowed.
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