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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Unexplained cash deposits in bank account were found genuine based on evidence of sale of land agreement, disclosure in audited books, and statements from involved parties clarifying no actual cash transaction took place due to fund transfer within same bank branch. Addition made by Assessing Officer on presumption basis was decided in favor of assessee. Interest paid on funds invested in immovable properties and shares of other companies was allowed as deduction, treating them as productive assets related to assessee's business, following coordinate bench decision. Unaccounted sales receipts were explained by voluntary disclosure during search and annexure showing receipts already considered for gross profit, leading to deletion of addition as sale receipts stood explained. Contradictory observations by authorities regarding treatment of same receipts were rectified in assessee's favor.
Unexplained cash deposits in bank account were found genuine based on evidence of sale of land agreement, disclosure in audited books, and statements from involved parties clarifying no actual cash transaction took place due to fund transfer within same bank branch. Addition made by Assessing Officer on presumption basis was decided in favor of assessee. Interest paid on funds invested in immovable properties and shares of other companies was allowed as deduction, treating them as productive assets related to assessee's business, following coordinate bench decision. Unaccounted sales receipts were explained by voluntary disclosure during search and annexure showing receipts already considered for gross profit, leading to deletion of addition as sale receipts stood explained. Contradictory observations by authorities regarding treatment of same receipts were rectified in assessee's favor.
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