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 partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
ITAT partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
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