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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Liquidated damages provision was disallowed as it was based on unascertained liability without probability of outflow of resources. ITAT deleted addition, holding provision arose from contractual obligation and estimation basis was reasonable based on past experience. Warranty provision at 2% of turnover based on past experience was appropriate, fulfilling accrual and matching concepts, unlike accounting expense in year incurred or on claim by customer. TPO's rectification enhancing income was void ab initio for lack of opportunity to assessee before enhancement u/s 154(3). ITAT's conclusion that services provided by AE were not stewardship services upheld. Questions 2.5 and 2.6 to be re-notified on 07.03.2024 for submissions.
Liquidated damages provision was disallowed as it was based on unascertained liability without probability of outflow of resources. ITAT deleted addition, holding provision arose from contractual obligation and estimation basis was reasonable based on past experience. Warranty provision at 2% of turnover based on past experience was appropriate, fulfilling accrual and matching concepts, unlike accounting expense in year incurred or on claim by customer. TPO's rectification enhancing income was void ab initio for lack of opportunity to assessee before enhancement u/s 154(3). ITAT's conclusion that services provided by AE were not stewardship services upheld. Questions 2.5 and 2.6 to be re-notified on 07.03.2024 for submissions.
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