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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Unexplained cash credits u/s 68 were added due to assessee's failure to discharge onus regarding bogus share capital including premium receipts. Despite filing confirmations and income tax details, the assessee could not justify abnormally high share premiums given its minimal commercial activity and poor financial health evident from profit and loss account. Four out of eleven share applicants were untraceable, one did not respond, and documents filed by remaining applicants were insufficient to prove genuineness of transactions. Considering case laws, assessee's financial condition, and inadequate onus discharge, Section 68 addition was confirmed, and assessee's appeal was dismissed.
Unexplained cash credits u/s 68 were added due to assessee's failure to discharge onus regarding bogus share capital including premium receipts. Despite filing confirmations and income tax details, the assessee could not justify abnormally high share premiums given its minimal commercial activity and poor financial health evident from profit and loss account. Four out of eleven share applicants were untraceable, one did not respond, and documents filed by remaining applicants were insufficient to prove genuineness of transactions. Considering case laws, assessee's financial condition, and inadequate onus discharge, Section 68 addition was confirmed, and assessee's appeal was dismissed.
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