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 overturned multiple additions made by AO regarding property transactions and unexplained cash receipts. On capital gains computation under s.50C, ITAT directed matter to DVO for fair market value determination, as circle rate adoption was disputed. Addition for alleged cash receipt was deleted due to lack of evidence and timing of property registration falling in subsequent assessment year. Regarding construction costs, cash flow statement requires AO's factual examination. Additions based on loose slips were deleted as documents lacked dates and definitive connection to assessment year. For s.68 addition concerning loan transaction, matter restored to AO for de novo adjudication considering assessee's explanation about generator sale. ITAT emphasized need for proper verification and evidence before making additions.
ITAT overturned multiple additions made by AO regarding property transactions and unexplained cash receipts. On capital gains computation under s.50C, ITAT directed matter to DVO for fair market value determination, as circle rate adoption was disputed. Addition for alleged cash receipt was deleted due to lack of evidence and timing of property registration falling in subsequent assessment year. Regarding construction costs, cash flow statement requires AO's factual examination. Additions based on loose slips were deleted as documents lacked dates and definitive connection to assessment year. For s.68 addition concerning loan transaction, matter restored to AO for de novo adjudication considering assessee's explanation about generator sale. ITAT emphasized need for proper verification and evidence before making additions.
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