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 that a partnership firm providing IPD services, room rentals, and diagnostic facilities does not qualify as engaging in medical profession under Section 44AD(6) and 44AA(1). The firm's income from facility services is distinct from doctors' professional fees, which are separately declared by individual practitioners. The tribunal accepted the firm's business income classification with net profit ratios between 6-11% of turnover, consistent with previous years' treatment. The addition proposed based on partner's statement was rejected as unwarranted since the remaining receipts were already treated as business income. The provisions of Section 44AD were held inapplicable to the firm's operations, and the assessee's appeal was allowed.
ITAT ruled that a partnership firm providing IPD services, room rentals, and diagnostic facilities does not qualify as engaging in medical profession under Section 44AD(6) and 44AA(1). The firm's income from facility services is distinct from doctors' professional fees, which are separately declared by individual practitioners. The tribunal accepted the firm's business income classification with net profit ratios between 6-11% of turnover, consistent with previous years' treatment. The addition proposed based on partner's statement was rejected as unwarranted since the remaining receipts were already treated as business income. The provisions of Section 44AD were held inapplicable to the firm's operations, and the assessee's appeal was allowed.
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