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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HC held that the amalgamated company was entitled to adjust the written down value of assets based on actual depreciation, despite not obtaining Central Government approval under Section 72A of the Income Tax Act. The Tribunal's previous order was overturned, affirming the CIT (Appeals) decision. The court found no public interest element in the amalgamation and ruled in favor of the assessee, allowing the adjustment of written down value and depreciation claim on amalgamating companies' assets. The substantial question of law was resolved against the Revenue, permitting the asset value adjustment without mandatory governmental approval.
HC held that the amalgamated company was entitled to adjust the written down value of assets based on actual depreciation, despite not obtaining Central Government approval under Section 72A of the Income Tax Act. The Tribunal's previous order was overturned, affirming the CIT (Appeals) decision. The court found no public interest element in the amalgamation and ruled in favor of the assessee, allowing the adjustment of written down value and depreciation claim on amalgamating companies' assets. The substantial question of law was resolved against the Revenue, permitting the asset value adjustment without mandatory governmental approval.
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