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 non-resident assessee company offered income on a presumptive basis u/s 44BB at 10% of gross receipts from a project office in India. The Assessing Officer accepted the returned income. Section 44BB, with its non-obstante clause, excludes the application of Sections 28 to 41 and Sections 43 and 43A, including Section 40(a)(i), for computing income from the business of exploration of mineral oils. The transactions were between two non-residents outside India. Following the Supreme Court's decision in CIT vs. Vantage International Management Co, service tax/GST receipts should not be included in the aggregate amounts u/s 44BB(2) since they are not received for services provided in prospecting, extraction or production of mineral oils. Consequently, the disallowance u/s 40(a)(i) was deleted, and the matter was decided in favor of the assessee.
The non-resident assessee company offered income on a presumptive basis u/s 44BB at 10% of gross receipts from a project office in India. The Assessing Officer accepted the returned income. Section 44BB, with its non-obstante clause, excludes the application of Sections 28 to 41 and Sections 43 and 43A, including Section 40(a)(i), for computing income from the business of exploration of mineral oils. The transactions were between two non-residents outside India. Following the Supreme Court's decision in CIT vs. Vantage International Management Co, service tax/GST receipts should not be included in the aggregate amounts u/s 44BB(2) since they are not received for services provided in prospecting, extraction or production of mineral oils. Consequently, the disallowance u/s 40(a)(i) was deleted, and the matter was decided in favor of the assessee.
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