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 based on loose papers containing coded figures, finding them to be mere scribbling without corroborative evidence to establish actual receipt of funds. The Tribunal confirmed deletion of cash seizure addition as the assessee had already disclosed Rs. 90 lacs against Rs. 8.93 lacs seized. Profit from sale of agricultural land was held exempt as evidence confirmed rural agricultural status outside municipal limits. Fresh credits were deleted as the assessee fulfilled Section 68 requirements by providing balance confirmations with PAN details. The Tribunal deleted jewelry addition by applying CBDT Instruction No.1916, which provides concessions for family members' jewelry holdings. Business-related expenses were allowed as they related to income-earning activities, while certain house property interest was disallowed for lack of supporting evidence.
The ITAT deleted additions based on loose papers containing coded figures, finding them to be mere scribbling without corroborative evidence to establish actual receipt of funds. The Tribunal confirmed deletion of cash seizure addition as the assessee had already disclosed Rs. 90 lacs against Rs. 8.93 lacs seized. Profit from sale of agricultural land was held exempt as evidence confirmed rural agricultural status outside municipal limits. Fresh credits were deleted as the assessee fulfilled Section 68 requirements by providing balance confirmations with PAN details. The Tribunal deleted jewelry addition by applying CBDT Instruction No.1916, which provides concessions for family members' jewelry holdings. Business-related expenses were allowed as they related to income-earning activities, while certain house property interest was disallowed for lack of supporting evidence.
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