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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The ITAT set aside CIT(A)'s order regarding unexplained investments under s.69 and additions under s.69A during the demonetization period. The case involved disputed bank deposits in Party A's account and statements recorded under s.131(1A). While the AO made additions based on partner statements and survey reports, they failed to follow mandatory CBDT SOPs and guidelines for demonetization cases. The Tribunal directed the AO to conduct fresh assessment following prescribed verification procedures, examine all evidence, and consider the assessee's claims in accordance with law. The ruling emphasized binding nature of CBDT circulars on tax officers and the necessity for uniform approach in handling demonetization-related assessments. Matter remanded for fresh consideration.
The ITAT set aside CIT(A)'s order regarding unexplained investments under s.69 and additions under s.69A during the demonetization period. The case involved disputed bank deposits in Party A's account and statements recorded under s.131(1A). While the AO made additions based on partner statements and survey reports, they failed to follow mandatory CBDT SOPs and guidelines for demonetization cases. The Tribunal directed the AO to conduct fresh assessment following prescribed verification procedures, examine all evidence, and consider the assessee's claims in accordance with law. The ruling emphasized binding nature of CBDT circulars on tax officers and the necessity for uniform approach in handling demonetization-related assessments. Matter remanded for fresh consideration.
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