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 on multiple issues in a tax assessment case. The Tribunal allowed 60% expenditure deduction against unaccounted cash receipts from spent solvents/scrap sales, following precedent from MSN Pharmachem Private Limited case. The court upheld AO's jurisdiction for notice under Section 153A, finding sufficient evidence of undisclosed income exceeding fifty lakh rupees. The Tribunal validated the assessment of 'on-money' payments for land purchase at Bibinagar, confirming that evidence from related party searches was admissible. However, the addition of deemed dividend under Section 2(22)(e) was set aside, directing AO to delete the addition following MSN Pharmachem precedent. The notice under Section 153A and subsequent assessment order were deemed valid under Section 153A(1).
ITAT ruled on multiple issues in a tax assessment case. The Tribunal allowed 60% expenditure deduction against unaccounted cash receipts from spent solvents/scrap sales, following precedent from MSN Pharmachem Private Limited case. The court upheld AO's jurisdiction for notice under Section 153A, finding sufficient evidence of undisclosed income exceeding fifty lakh rupees. The Tribunal validated the assessment of 'on-money' payments for land purchase at Bibinagar, confirming that evidence from related party searches was admissible. However, the addition of deemed dividend under Section 2(22)(e) was set aside, directing AO to delete the addition following MSN Pharmachem precedent. The notice under Section 153A and subsequent assessment order were deemed valid under Section 153A(1).
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