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 remanded several issues back to AO for verification including disallowances under sections 14A, 43B, and 35. The Tribunal allowed the assessee's appeal regarding signing amount of grant received, treating it as a liability pending project execution. Foreign commission expenditure was ruled in favor of the assessee, finding no TDS applicability under section 195 as services were rendered outside India. Exchange fluctuation matters were restored to AO for examination under section 43A to determine treatment of capital assets versus WIP. Section 35(2AB) deduction claim was remanded for verification of DSIR approval and compliance. The Tribunal emphasized proper verification of evidence and mandated opportunity of hearing following principles of natural justice across remanded issues.
ITAT remanded several issues back to AO for verification including disallowances under sections 14A, 43B, and 35. The Tribunal allowed the assessee's appeal regarding signing amount of grant received, treating it as a liability pending project execution. Foreign commission expenditure was ruled in favor of the assessee, finding no TDS applicability under section 195 as services were rendered outside India. Exchange fluctuation matters were restored to AO for examination under section 43A to determine treatment of capital assets versus WIP. Section 35(2AB) deduction claim was remanded for verification of DSIR approval and compliance. The Tribunal emphasized proper verification of evidence and mandated opportunity of hearing following principles of natural justice across remanded issues.
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