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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ITAT ruled against disallowance of transportation expenses, finding the Assessing Officer failed to establish statutory grounds u/s 37 for rejection. The tribunal emphasized that disallowance requires proving either bogus claims, capital/personal expenditure nature, or illegality of expense. Evidence showed consistent business pattern with progressive GP/NP rates compared to previous years where similar deductions were allowed. AO's summary disallowance without substantiating any Section 37 violations was deemed unjustified. The tribunal vacated CIT(A)'s order sustaining the disallowance, ruling in assessee's favor by accepting the claimed transportation expenses as legitimate business deductions.
ITAT ruled against disallowance of transportation expenses, finding the Assessing Officer failed to establish statutory grounds u/s 37 for rejection. The tribunal emphasized that disallowance requires proving either bogus claims, capital/personal expenditure nature, or illegality of expense. Evidence showed consistent business pattern with progressive GP/NP rates compared to previous years where similar deductions were allowed. AO's summary disallowance without substantiating any Section 37 violations was deemed unjustified. The tribunal vacated CIT(A)'s order sustaining the disallowance, ruling in assessee's favor by accepting the claimed transportation expenses as legitimate business deductions.
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