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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Deduction u/s 10A - loss on account of foreign exchange fluctuation while computing deductions: CIT(A) order against assessee attained finality as assessee did not challenge it. IT department's ground misconceived as it did not arise from ITAT order. Telecommunication expenditure excluded from export and total turnover for computing deduction u/s 10A as per SC judgment in CIT vs HCL Technologies Ltd, allowing exclusion of foreign exchange expenses for providing technical services outside India.
Deduction u/s 10A - loss on account of foreign exchange fluctuation while computing deductions: CIT(A) order against assessee attained finality as assessee did not challenge it. IT department's ground misconceived as it did not arise from ITAT order. Telecommunication expenditure excluded from export and total turnover for computing deduction u/s 10A as per SC judgment in CIT vs HCL Technologies Ltd, allowing exclusion of foreign exchange expenses for providing technical services outside India.
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