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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Legal principles regarding raising new grounds in an appeal before tax authorities, and the treatment of interest income earned on compulsory deposits of share application or subscription money. The Supreme Court held that tax authorities cannot take a narrow view and prevent an assessee from raising new grounds, as long as the relevant facts are on record and the ground is raised bona fide. Regarding interest income, the Supreme Court ruled that interest earned on compulsory deposits made for share issue is incidental and should be set off against share issue expenses, since the purpose of deposit is compliance with statutory requirements, not earning income. The court decisions favored the assessee's position on both issues.
Legal principles regarding raising new grounds in an appeal before tax authorities, and the treatment of interest income earned on compulsory deposits of share application or subscription money. The Supreme Court held that tax authorities cannot take a narrow view and prevent an assessee from raising new grounds, as long as the relevant facts are on record and the ground is raised bona fide. Regarding interest income, the Supreme Court ruled that interest earned on compulsory deposits made for share issue is incidental and should be set off against share issue expenses, since the purpose of deposit is compliance with statutory requirements, not earning income. The court decisions favored the assessee's position on both issues.
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