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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The assessee admitted certain income amounts under different heads like income from house property and income from other sources while filing the return. However, the amount was shown in the tax audit report as 'any other items of income' but not mentioned in the corresponding column of the return. The CPC made an addition under 'income from business or profession' based on this discrepancy. The ITAT held that since the assessee had already admitted and included these amounts under the respective heads, it was not necessary to mention them again under 'any other items of income'. Therefore, the addition made by the AO/CPC under 'income from business or profession' was not warranted and was set aside by the ITAT.
The assessee admitted certain income amounts under different heads like income from house property and income from other sources while filing the return. However, the amount was shown in the tax audit report as 'any other items of income' but not mentioned in the corresponding column of the return. The CPC made an addition under 'income from business or profession' based on this discrepancy. The ITAT held that since the assessee had already admitted and included these amounts under the respective heads, it was not necessary to mention them again under 'any other items of income'. Therefore, the addition made by the AO/CPC under 'income from business or profession' was not warranted and was set aside by the ITAT.
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