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 CIT(A)'s deletion of multiple additions made against the assessee regarding unaccounted money lending, payments, jewellery, and chit fund transactions. The tribunal found that substantive additions were correctly made in M/s Bulland Buildtech Pvt. Ltd.'s hands, not the assessee's. Ancestral jewellery was within CBDT prescribed limits. Personal expenditure was justified from own funds without evidence of undisclosed income. Cash balance of Rs. 1,62,000 was properly declared. Payments related to M/s Bulland Leasing and Finance Ltd. for AY 2007-08 couldn't be added in AY 2011-12. Revenue's appeals were dismissed due to tax effects below monetary limits per CBDT Circular No.17/2019. All grounds raised by revenue were rejected, ruling in assessee's favor.
ITAT upheld CIT(A)'s deletion of multiple additions made against the assessee regarding unaccounted money lending, payments, jewellery, and chit fund transactions. The tribunal found that substantive additions were correctly made in M/s Bulland Buildtech Pvt. Ltd.'s hands, not the assessee's. Ancestral jewellery was within CBDT prescribed limits. Personal expenditure was justified from own funds without evidence of undisclosed income. Cash balance of Rs. 1,62,000 was properly declared. Payments related to M/s Bulland Leasing and Finance Ltd. for AY 2007-08 couldn't be added in AY 2011-12. Revenue's appeals were dismissed due to tax effects below monetary limits per CBDT Circular No.17/2019. All grounds raised by revenue were rejected, ruling in assessee's favor.
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