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 High Court found that the Income Tax Appellate Tribunal's order regarding the source of cash gifts was perverse and failed to consider the available evidence. The bank statement of the Privy Purse account clearly showed that cheques and cash totaling Rs. 10 lakh were released from this account to the two trusts on various dates. Therefore, the court held that the gift amount was made out of the Privy Purse, requiring further adjudication. The court's decision favored the assessee, overturning the Tribunal's order on this issue.
The High Court found that the Income Tax Appellate Tribunal's order regarding the source of cash gifts was perverse and failed to consider the available evidence. The bank statement of the Privy Purse account clearly showed that cheques and cash totaling Rs. 10 lakh were released from this account to the two trusts on various dates. Therefore, the court held that the gift amount was made out of the Privy Purse, requiring further adjudication. The court's decision favored the assessee, overturning the Tribunal's order on this issue.
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