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 dismissed Revenue's appeal regarding addition for under-valuation of closing work-in-progress. Following precedent from a Coordinate Bench, the Tribunal held that SS145A requires inventory valuation at lower of actual cost or net realizable value, and excise duty should not be included in closing WIP as no such amount was paid since the stage of levy had not arisen. Regarding disallowance under SS43B for bonus/ex-gratia payments, ITAT upheld CIT(A)'s direction to AO to verify whether payments were made before the filing deadline (30/11/2018), characterizing this as limited verification rather than remand. The Tribunal confirmed that SS43B emphasizes actual payment before the return filing date with proper evidence furnished by the assessee.
The ITAT dismissed Revenue's appeal regarding addition for under-valuation of closing work-in-progress. Following precedent from a Coordinate Bench, the Tribunal held that SS145A requires inventory valuation at lower of actual cost or net realizable value, and excise duty should not be included in closing WIP as no such amount was paid since the stage of levy had not arisen. Regarding disallowance under SS43B for bonus/ex-gratia payments, ITAT upheld CIT(A)'s direction to AO to verify whether payments were made before the filing deadline (30/11/2018), characterizing this as limited verification rather than remand. The Tribunal confirmed that SS43B emphasizes actual payment before the return filing date with proper evidence furnished by the assessee.
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