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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Charitable society received cash credits from a non-resident individual, offered as taxable income. AO doubted credibility of donor based on his wife's statement about monthly expenses. ITAT held donor's non-taxability in separate assessment u/ss 153C and 144 lends credence to transaction. Society's charitable nature, public utility works undisputed. Mere suspicion based on donor's association insufficient to treat him as conduit. Wife's unawareness about donations renders reliance on her statement unjustified. Lack of corroborative evidence from Gupta brothers' search precludes treating donor as conduit. Affidavit possessed by assessee supports donation. Revenue's grounds rejected, decided in assessee's favor.
Charitable society received cash credits from a non-resident individual, offered as taxable income. AO doubted credibility of donor based on his wife's statement about monthly expenses. ITAT held donor's non-taxability in separate assessment u/ss 153C and 144 lends credence to transaction. Society's charitable nature, public utility works undisputed. Mere suspicion based on donor's association insufficient to treat him as conduit. Wife's unawareness about donations renders reliance on her statement unjustified. Lack of corroborative evidence from Gupta brothers' search precludes treating donor as conduit. Affidavit possessed by assessee supports donation. Revenue's grounds rejected, decided in assessee's favor.
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