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...
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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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Assessee's claims allowed: 1) Sales promotion expenses booked on gross basis and settled on actual utilization basis as per matching principle and regularly followed accounting method. 2) Insurance expenditure paid to National Insurance Company for enhancing sum insured and part of premium policy already paid. 3) Interest on delayed payment treated as allowable financial charge, being in nature of revenue expenditure and not connected to acquisition of capital asset.
Assessee's claims allowed: 1) Sales promotion expenses booked on gross basis and settled on actual utilization basis as per matching principle and regularly followed accounting method. 2) Insurance expenditure paid to National Insurance Company for enhancing sum insured and part of premium policy already paid. 3) Interest on delayed payment treated as allowable financial charge, being in nature of revenue expenditure and not connected to acquisition of capital asset.
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