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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CIT(A) did not violate Rule 46A by admitting evidence not produced before AO, as Rule 46(4) permits Appellate Authority to call for evidence. CIT(A) rightly deleted addition of Rs. 60 lakh unsecured loan from mother u/s 68, after examining relevant material. CIT(A) correctly deleted addition of sundry creditors u/s 68, as most were paid in subsequent years and formed part of business transactions. No addition tenable u/s 41(1) for sundry creditors. CIT(A) rightly restricted income estimation to 6% of turnover. Revenue's appeal dismissed by ITAT.
CIT(A) did not violate Rule 46A by admitting evidence not produced before AO, as Rule 46(4) permits Appellate Authority to call for evidence. CIT(A) rightly deleted addition of Rs. 60 lakh unsecured loan from mother u/s 68, after examining relevant material. CIT(A) correctly deleted addition of sundry creditors u/s 68, as most were paid in subsequent years and formed part of business transactions. No addition tenable u/s 41(1) for sundry creditors. CIT(A) rightly restricted income estimation to 6% of turnover. Revenue's appeal dismissed by ITAT.
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