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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Disallowance for prepaid finance charges was deleted as the Tribunal in the assessee's own case for the previous year had allowed deduction for finance charges including prepaid finance charges in the year of payment itself. Excess interest spread income earned on assignment of receivables was deleted following the Tribunal's decision in the assessee's own case for a different year. Regarding provision for bad and doubtful debts u/s 36(1)(viia)(d), the deduction cannot exceed 5% of total income, and the differential amount disallowed by the AO was confirmed. The alternative claim regarding reversal of provision for standard assets and diminution in value of investments was remanded back to the AO for fresh adjudication as facts were not examined. The Appellate Tribunal's decision was cited.
Disallowance for prepaid finance charges was deleted as the Tribunal in the assessee's own case for the previous year had allowed deduction for finance charges including prepaid finance charges in the year of payment itself. Excess interest spread income earned on assignment of receivables was deleted following the Tribunal's decision in the assessee's own case for a different year. Regarding provision for bad and doubtful debts u/s 36(1)(viia)(d), the deduction cannot exceed 5% of total income, and the differential amount disallowed by the AO was confirmed. The alternative claim regarding reversal of provision for standard assets and diminution in value of investments was remanded back to the AO for fresh adjudication as facts were not examined. The Appellate Tribunal's decision was cited.
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