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 AO's jurisdiction to examine undisclosed share transaction investments under limited scrutiny assessment. AO's examination of unsecured loans was deemed valid as investments were funded through loans, necessitating verification of creditors' genuineness and creditworthiness. Regarding Rs. 21 lakhs loan from spouse secured against property, ITAT remanded matter to AO for detailed verification of loan creditors and documentation. While assessee provided affidavits, insufficient evidence existed to establish creditors' creditworthiness. AO directed to verify loan credits and issue necessary summons to creditors. First ground of appeal dismissed, second ground partially allowed for statistical purposes.
ITAT upheld AO's jurisdiction to examine undisclosed share transaction investments under limited scrutiny assessment. AO's examination of unsecured loans was deemed valid as investments were funded through loans, necessitating verification of creditors' genuineness and creditworthiness. Regarding Rs. 21 lakhs loan from spouse secured against property, ITAT remanded matter to AO for detailed verification of loan creditors and documentation. While assessee provided affidavits, insufficient evidence existed to establish creditors' creditworthiness. AO directed to verify loan credits and issue necessary summons to creditors. First ground of appeal dismissed, second ground partially allowed for statistical purposes.
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