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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Observing that property details were provided to the Assessing Officer, properties reflected in accounts submitted during assessment proceedings, substantial payment made in 2010, and cash component part of purchase deed submitted to AO, the Tribunal held that Assessment Order was not erroneous prejudicial to Revenue interest. Consequently, Order u/s 263 set aside, allowing assessee's appeal.
Observing that property details were provided to the Assessing Officer, properties reflected in accounts submitted during assessment proceedings, substantial payment made in 2010, and cash component part of purchase deed submitted to AO, the Tribunal held that Assessment Order was not erroneous prejudicial to Revenue interest. Consequently, Order u/s 263 set aside, allowing assessee's appeal.
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