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 in favor of assessee regarding GST disallowance u/s 43B. The tribunal found that GST amount was not routed through Profit & Loss account but shown under current liabilities, which remained uncontroverted by Revenue. No evidence was presented to demonstrate that assessee claimed any deduction for GST. Following established precedent, where tax liability is neither claimed as deduction nor debited to P&L account, provisions of section 43B are not applicable. Therefore, disallowance cannot be sustained when no deduction was claimed in the first place. Revenue's appeal dismissed.
ITAT ruled in favor of assessee regarding GST disallowance u/s 43B. The tribunal found that GST amount was not routed through Profit & Loss account but shown under current liabilities, which remained uncontroverted by Revenue. No evidence was presented to demonstrate that assessee claimed any deduction for GST. Following established precedent, where tax liability is neither claimed as deduction nor debited to P&L account, provisions of section 43B are not applicable. Therefore, disallowance cannot be sustained when no deduction was claimed in the first place. Revenue's appeal dismissed.
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