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 that expenditure on machinery replacement was revenue in nature as production capacity remained constant across factories. While benefits under Section 35(i)(iv) were denied following precedent, the court granted 100% depreciation for fly ash silos as pollution control equipment since they effectively contained and evacuated pollutants by channeling fly ash into production processes. The assessee's claim for interest deduction under Section 43B failed due to lack of evidence proving actual payment. Regarding Section 80HHC deductions, the court ruled in the assessee's favor, holding that excise duty, customs duty, and windmill power receipts form part of total turnover. However, the claim for full depreciation on dumpers was rejected as the assessee failed to prove possession or use prior to October 1, 1995.
The HC ruled that expenditure on machinery replacement was revenue in nature as production capacity remained constant across factories. While benefits under Section 35(i)(iv) were denied following precedent, the court granted 100% depreciation for fly ash silos as pollution control equipment since they effectively contained and evacuated pollutants by channeling fly ash into production processes. The assessee's claim for interest deduction under Section 43B failed due to lack of evidence proving actual payment. Regarding Section 80HHC deductions, the court ruled in the assessee's favor, holding that excise duty, customs duty, and windmill power receipts form part of total turnover. However, the claim for full depreciation on dumpers was rejected as the assessee failed to prove possession or use prior to October 1, 1995.
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