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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Section 50C's multiplicative rate applicability was challenged. The Income Tax Appellate Tribunal affirmed the Commissioner's order applying a factor of "1" to the property sold by the assessee. However, the Tribunal failed to provide reasoning, even rudimentary, for affirming the Commissioner's findings. Consequently, the High Court allowed the appeal, set aside the Tribunal's order, and remanded the matter for fresh adjudication by the Tribunal, leaving all questions open for consideration.
Section 50C's multiplicative rate applicability was challenged. The Income Tax Appellate Tribunal affirmed the Commissioner's order applying a factor of "1" to the property sold by the assessee. However, the Tribunal failed to provide reasoning, even rudimentary, for affirming the Commissioner's findings. Consequently, the High Court allowed the appeal, set aside the Tribunal's order, and remanded the matter for fresh adjudication by the Tribunal, leaving all questions open for consideration.
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