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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HC reversed Tribunal's ruling on Section 80IC deduction eligibility. Unlike Section 80IA, Section 80IC(2)(b)(ii) does not mandate agreement with Central/State Government or local authority as prerequisite for tax benefits. Court distinguished between Section 80IC(2)(a), requiring compliance with Central Government schemes, and 80IC(2)(b), which only necessitates manufacturing specified items in designated states within prescribed periods. Tribunal erroneously applied Rule 18BBB and Form 10CCB requirements, which cover multiple provisions (80I, 80IA, 80IB, 80IC). Additionally, Tribunal's examination of abnormal profits under Section 80IA(8) and 80IA(10) was procedurally improper as these issues weren't previously raised before AO or CIT(A). Appeal allowed in favor of assessee.
HC reversed Tribunal's ruling on Section 80IC deduction eligibility. Unlike Section 80IA, Section 80IC(2)(b)(ii) does not mandate agreement with Central/State Government or local authority as prerequisite for tax benefits. Court distinguished between Section 80IC(2)(a), requiring compliance with Central Government schemes, and 80IC(2)(b), which only necessitates manufacturing specified items in designated states within prescribed periods. Tribunal erroneously applied Rule 18BBB and Form 10CCB requirements, which cover multiple provisions (80I, 80IA, 80IB, 80IC). Additionally, Tribunal's examination of abnormal profits under Section 80IA(8) and 80IA(10) was procedurally improper as these issues weren't previously raised before AO or CIT(A). Appeal allowed in favor of assessee.
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