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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Non-resident Indian donor gifted funds to assessee through cheques from NRE account, proving identity, creditworthiness, and genuineness. Assessing Officer made addition to assessee's income by treating gift as income, which was incorrect as gift from relative is not taxable. Interest income from other sources was also doubly added by AO while processing return, leading to double taxation. ITAT directed AO to delete both additions as gift was genuine and interest income was already included in return, allowing assessee's appeals on both grounds.
Non-resident Indian donor gifted funds to assessee through cheques from NRE account, proving identity, creditworthiness, and genuineness. Assessing Officer made addition to assessee's income by treating gift as income, which was incorrect as gift from relative is not taxable. Interest income from other sources was also doubly added by AO while processing return, leading to double taxation. ITAT directed AO to delete both additions as gift was genuine and interest income was already included in return, allowing assessee's appeals on both grounds.
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