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 Income Tax Appellate Tribunal held that the assessee had reasonably discharged its onus to explain the loan credit by adducing proper legal evidence. The loan amount received from M/s. Abhilasha Shoppers Pvt. Ltd. was verifiable from the financial statements, TDS certificates, and bank statements. The repayment of loan along with interest was made through proper banking channels. The general statements recorded by the Investigation Wing were not specific to the assessee's case. Consequently, the Tribunal set aside the additions made u/s 68 and allowed the deduction of interest paid on the loan, following the decision in M/s. Vibrant Global Capital Ltd.
The Income Tax Appellate Tribunal held that the assessee had reasonably discharged its onus to explain the loan credit by adducing proper legal evidence. The loan amount received from M/s. Abhilasha Shoppers Pvt. Ltd. was verifiable from the financial statements, TDS certificates, and bank statements. The repayment of loan along with interest was made through proper banking channels. The general statements recorded by the Investigation Wing were not specific to the assessee's case. Consequently, the Tribunal set aside the additions made u/s 68 and allowed the deduction of interest paid on the loan, following the decision in M/s. Vibrant Global Capital Ltd.
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