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 deleted additions related to dividend and interest income, holding that dividend could not be assessed in the hands of the appellant for unregistered shares, especially considering the shares belonged to a notified person under custody of the Special Court. Additions for unexplained share investments were deleted after considering bonus shares. Interest income additions were also deleted as relevant documents were in possession of the Income Tax Department or Custodian. Various expense disallowances including interest on debenture call money and share trading losses were reversed, with the Tribunal finding that accounting and auditing expenses were incurred for business purposes and therefore allowable. Following its earlier decision in the appellant's case for AY 1991-92, the ITAT directed the AO to allow the entire claim of interest expenditure.
The ITAT deleted additions related to dividend and interest income, holding that dividend could not be assessed in the hands of the appellant for unregistered shares, especially considering the shares belonged to a notified person under custody of the Special Court. Additions for unexplained share investments were deleted after considering bonus shares. Interest income additions were also deleted as relevant documents were in possession of the Income Tax Department or Custodian. Various expense disallowances including interest on debenture call money and share trading losses were reversed, with the Tribunal finding that accounting and auditing expenses were incurred for business purposes and therefore allowable. Following its earlier decision in the appellant's case for AY 1991-92, the ITAT directed the AO to allow the entire claim of interest expenditure.
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