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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This case deals with various issues related to deductions and allowances under the Income Tax Act. The key points are: Deduction u/s 80IB for profits from an industrial unit was allowed based on separate profit and loss account filed. Deduction u/s 80HHC for export profits was allowed, as the retrospective amendment disallowing deduction for DEPB license sale was struck down. Disallowance of commission paid was set aside for lack of evidence. Expenditure on repairs and replacements of plant and machinery was held allowable as revenue expenditure u/s 31. Service charges paid to a group company were held allowable. Community development expenses were treated as business expenditure. Entrance fees paid to clubs for employee welfare were held allowable. Short-term capital loss on sale of investments was directed to be re-examined for allowability. Expenditure on aircraft maintenance and depreciation during trial run was allowed. Deduction u/s 80HHC was remanded for computation based on book profits. Market value for transfer pricing u/s 80IA was accepted. Disallowance of repair expenses on an estimated basis was set aside. Write-back of provision was held non-taxable as already offered earlier.
This case deals with various issues related to deductions and allowances under the Income Tax Act. The key points are: Deduction u/s 80IB for profits from an industrial unit was allowed based on separate profit and loss account filed. Deduction u/s 80HHC for export profits was allowed, as the retrospective amendment disallowing deduction for DEPB license sale was struck down. Disallowance of commission paid was set aside for lack of evidence. Expenditure on repairs and replacements of plant and machinery was held allowable as revenue expenditure u/s 31. Service charges paid to a group company were held allowable. Community development expenses were treated as business expenditure. Entrance fees paid to clubs for employee welfare were held allowable. Short-term capital loss on sale of investments was directed to be re-examined for allowability. Expenditure on aircraft maintenance and depreciation during trial run was allowed. Deduction u/s 80HHC was remanded for computation based on book profits. Market value for transfer pricing u/s 80IA was accepted. Disallowance of repair expenses on an estimated basis was set aside. Write-back of provision was held non-taxable as already offered earlier.
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