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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Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
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