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 addressed exemption claim under section 10(26AAA) regarding unexplained cash withdrawals in FY 2017-18. While CIT(A) upheld AO's denial of Sikkimese exemption, it improperly admitted additional evidence under Rule 46A and classified deposits as contract income without giving AO hearing opportunity. Given new documentation presented at ITAT stage not previously available to AO, matter remanded for de novo assessment. ITAT clarified that for 10(26AAA) exemption, both Sikkimese status and Sikkim-sourced income must be established. Assessee permitted to present all relevant submissions supporting exemption claim during fresh assessment. Both assessee's and Revenue's appeals allowed for statistical purposes.
ITAT addressed exemption claim under section 10(26AAA) regarding unexplained cash withdrawals in FY 2017-18. While CIT(A) upheld AO's denial of Sikkimese exemption, it improperly admitted additional evidence under Rule 46A and classified deposits as contract income without giving AO hearing opportunity. Given new documentation presented at ITAT stage not previously available to AO, matter remanded for de novo assessment. ITAT clarified that for 10(26AAA) exemption, both Sikkimese status and Sikkim-sourced income must be established. Assessee permitted to present all relevant submissions supporting exemption claim during fresh assessment. Both assessee's and Revenue's appeals allowed for statistical purposes.
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