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 claimed expenditure relating to financial advisor's fees, which was disallowed u/s 57(iii) as it did not relate to earning such income. However, the CIT(A) deleted the addition, and the ITAT upheld the CIT(A)'s order, following the Supreme Court's judgment in Rajendra Prasad Moody's case, as the assessee had a legal dispute pending related to earning income during the year. Regarding the disallowance u/s 37(1) for expenses incurred on bills/vouchers, the ITAT rejected the Revenue's ground, as the AO made an ad-hoc disallowance without pointing out any specific element of such expenditure. The CIT(A) rightly deleted the ad-hoc disallowance, as the expenses were necessary and genuine for the business or profession, as substantiated by the assessee.
The assessee claimed expenditure relating to financial advisor's fees, which was disallowed u/s 57(iii) as it did not relate to earning such income. However, the CIT(A) deleted the addition, and the ITAT upheld the CIT(A)'s order, following the Supreme Court's judgment in Rajendra Prasad Moody's case, as the assessee had a legal dispute pending related to earning income during the year. Regarding the disallowance u/s 37(1) for expenses incurred on bills/vouchers, the ITAT rejected the Revenue's ground, as the AO made an ad-hoc disallowance without pointing out any specific element of such expenditure. The CIT(A) rightly deleted the ad-hoc disallowance, as the expenses were necessary and genuine for the business or profession, as substantiated by the assessee.
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