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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No exempt income earned, hence no disallowance u/s 14A permissible up to AY 2021-22; however, from AY 2022-23 onwards, disallowance relating to exempt income allowable even if no exempt income earned due to inserted Explanation. GST input credit allowable as deduction if not embedded in cost of goods/services; else revenue neutral. AO directed to allow GST deduction after verifying not claimed in P&L with corresponding cost entries, subject to Wipro and Shri Ram Investments decisions of SC. Assessee's appeal allowed for limited remand to AO on GST issue.
No exempt income earned, hence no disallowance u/s 14A permissible up to AY 2021-22; however, from AY 2022-23 onwards, disallowance relating to exempt income allowable even if no exempt income earned due to inserted Explanation. GST input credit allowable as deduction if not embedded in cost of goods/services; else revenue neutral. AO directed to allow GST deduction after verifying not claimed in P&L with corresponding cost entries, subject to Wipro and Shri Ram Investments decisions of SC. Assessee's appeal allowed for limited remand to AO on GST issue.
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