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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Income Tax: Limit of remuneration to working partners in partnership firms allowed as deduction increased - on first Rs 6,00,000 of book profit or loss, Rs 3,00,000 or 90% of book profit, whichever higher; on balance book profit, 60%. Amendment to Section 40(b)(v) effective from April 1, 2025 for assessment year 2025-2026 onwards. Existing limit Rs 1,50,000 or 90% of book profit on first Rs 3,00,000, 60% on balance.
Income Tax: Limit of remuneration to working partners in partnership firms allowed as deduction increased - on first Rs 6,00,000 of book profit or loss, Rs 3,00,000 or 90% of book profit, whichever higher; on balance book profit, 60%. Amendment to Section 40(b)(v) effective from April 1, 2025 for assessment year 2025-2026 onwards. Existing limit Rs 1,50,000 or 90% of book profit on first Rs 3,00,000, 60% on balance.
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