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 upheld application of higher tax rate (60%) u/s 115BBE for unexplained cash deposits treated as deemed income u/s 68. The Tribunal confirmed that enhanced tax rates apply to entire previous year 2016-17 (AY 2017-18), rejecting appellant's contention against retrospective application. Distinguishing between charging provisions and machinery provisions, ITAT clarified that while charging provisions cannot apply retrospectively, tax rates specified in Schedule are applicable as determined annually by Parliament. Following precedent in Chandan Garments Pvt Ltd case, ITAT found AO's tax computation at higher rate legally valid and dismissed the appeal.
ITAT upheld application of higher tax rate (60%) u/s 115BBE for unexplained cash deposits treated as deemed income u/s 68. The Tribunal confirmed that enhanced tax rates apply to entire previous year 2016-17 (AY 2017-18), rejecting appellant's contention against retrospective application. Distinguishing between charging provisions and machinery provisions, ITAT clarified that while charging provisions cannot apply retrospectively, tax rates specified in Schedule are applicable as determined annually by Parliament. Following precedent in Chandan Garments Pvt Ltd case, ITAT found AO's tax computation at higher rate legally valid and dismissed the appeal.
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