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 ITAT upheld the CIT(A)'s deletion of additions made by the AO regarding alleged bogus charges for installation of electricity poles and purchases. The Tribunal found that the CIT(A) had meticulously examined evidence from each vendor, and the AO failed to demonstrate any perversity in the CIT(A)'s assessment. The ITAT also confirmed deletion of additions related to cash found in a locker, acknowledging it represented company funds reflected in imprest accounts. Additionally, the Tribunal sustained the CIT(A)'s allowance of bad debts written off by the assessee, recognizing that MCD had refused payments due to investigations into Commonwealth Games 2010 contracts, making the debts reasonably uncollectible despite legal remedies not being exhausted.
The ITAT upheld the CIT(A)'s deletion of additions made by the AO regarding alleged bogus charges for installation of electricity poles and purchases. The Tribunal found that the CIT(A) had meticulously examined evidence from each vendor, and the AO failed to demonstrate any perversity in the CIT(A)'s assessment. The ITAT also confirmed deletion of additions related to cash found in a locker, acknowledging it represented company funds reflected in imprest accounts. Additionally, the Tribunal sustained the CIT(A)'s allowance of bad debts written off by the assessee, recognizing that MCD had refused payments due to investigations into Commonwealth Games 2010 contracts, making the debts reasonably uncollectible despite legal remedies not being exhausted.
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