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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The HC ruled against the approach of estimating profit (at 12.5%) on bogus purchases, finding it contradictory to Section 69C of the Income Tax Act. The court reasoned that estimating profit on unproven purchases effectively grants partial deduction for those purchases, which Section 69C expressly prohibits for unexplained expenditures. The court partially ruled in favor of the revenue department regarding purchases from Neptune Trading Co. and Hari Om Traders, while ruling in favor of the assessee regarding purchases from other suppliers. The court capped the total additions at Rs. 1,00,10,773, representing the total purchases from the two specified parties, and reversed the CIT(A) and Tribunal orders to that extent.
The HC ruled against the approach of estimating profit (at 12.5%) on bogus purchases, finding it contradictory to Section 69C of the Income Tax Act. The court reasoned that estimating profit on unproven purchases effectively grants partial deduction for those purchases, which Section 69C expressly prohibits for unexplained expenditures. The court partially ruled in favor of the revenue department regarding purchases from Neptune Trading Co. and Hari Om Traders, while ruling in favor of the assessee regarding purchases from other suppliers. The court capped the total additions at Rs. 1,00,10,773, representing the total purchases from the two specified parties, and reversed the CIT(A) and Tribunal orders to that extent.
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