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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Interest income earned on government grants parked in bank accounts for Smart City project implementation was contested. Assessee, established for Smart City Scheme execution, maintained separate accounts for Central and State Government funds. Interest earned on Central Government funds was returned to Consolidated Fund of India per GFR Rule 230(8), while State Government fund interest was adjusted against subsequent grants. ITAT remanded matter to AO for verification of interest remittance to respective governments. If confirmed that assessee retained no revenue benefit and interest was fully remitted, no addition should be made for interest income earned on deposits (fixed deposits and savings accounts). Matter requires factual verification of fund utilization and interest disposition as per governmental guidelines.
Interest income earned on government grants parked in bank accounts for Smart City project implementation was contested. Assessee, established for Smart City Scheme execution, maintained separate accounts for Central and State Government funds. Interest earned on Central Government funds was returned to Consolidated Fund of India per GFR Rule 230(8), while State Government fund interest was adjusted against subsequent grants. ITAT remanded matter to AO for verification of interest remittance to respective governments. If confirmed that assessee retained no revenue benefit and interest was fully remitted, no addition should be made for interest income earned on deposits (fixed deposits and savings accounts). Matter requires factual verification of fund utilization and interest disposition as per governmental guidelines.
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