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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT determined MAT provisions under s.115JB were inapplicable to electricity companies governed by specific statutes before the 2013 amendment, regardless of incorporation status. Following Raj. HC precedent in Ajmer Vidyut case, the tribunal rejected CIT(A)'s interpretation that excluded only power generation companies under s.115JA(iv). The legislative history confirmed electricity companies were not intended for MAT coverage pre-2012. The tribunal allowed the assessee's appeals, deleting additions to book profits under s.115JB for both assessment years, emphasizing that companies operating under distinct electricity statutes remained outside MAT's scope until the specific amendment effective April 1, 2013.
ITAT determined MAT provisions under s.115JB were inapplicable to electricity companies governed by specific statutes before the 2013 amendment, regardless of incorporation status. Following Raj. HC precedent in Ajmer Vidyut case, the tribunal rejected CIT(A)'s interpretation that excluded only power generation companies under s.115JA(iv). The legislative history confirmed electricity companies were not intended for MAT coverage pre-2012. The tribunal allowed the assessee's appeals, deleting additions to book profits under s.115JB for both assessment years, emphasizing that companies operating under distinct electricity statutes remained outside MAT's scope until the specific amendment effective April 1, 2013.
Note: It is a system-generated summary and is for quick reference only.