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 affirmed weighted deduction eligibility u/s 35(2AB) for in-house scientific research expenditure. While R&D expenses incurred within India qualify for weighted deduction, foreign R&D capital expenditure is allowable u/s 35(1)(iv). The Tribunal distinguished between domestic and international research expenses, maintaining that revenue R&D expenditure incurred outside India was already permitted in the assessment. Product development expenses were classified as revenue expenses. The ruling establishes clear parameters for tax treatment of research expenditure based on geographical location and nature of expense, overturning AO's blanket disallowance of foreign expenditure.
ITAT affirmed weighted deduction eligibility u/s 35(2AB) for in-house scientific research expenditure. While R&D expenses incurred within India qualify for weighted deduction, foreign R&D capital expenditure is allowable u/s 35(1)(iv). The Tribunal distinguished between domestic and international research expenses, maintaining that revenue R&D expenditure incurred outside India was already permitted in the assessment. Product development expenses were classified as revenue expenses. The ruling establishes clear parameters for tax treatment of research expenditure based on geographical location and nature of expense, overturning AO's blanket disallowance of foreign expenditure.
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