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 held that the CIT(A) correctly deleted disallowances related to inter-branch purchases after reviewing the Remand Report. The Revenue's challenge was deemed unsustainable as the Assessing Officer had already accepted the assessee's claim following document verification. Relying on precedent from Bombay HC, the tribunal emphasized that once concessions are made and verified, the department cannot subsequently challenge the same. The appeal was found devoid of merit, with the cross objection deemed unnecessary as no substantive grievance existed against the original order. The decision affirmed procedural fairness in tax assessment proceedings.
ITAT held that the CIT(A) correctly deleted disallowances related to inter-branch purchases after reviewing the Remand Report. The Revenue's challenge was deemed unsustainable as the Assessing Officer had already accepted the assessee's claim following document verification. Relying on precedent from Bombay HC, the tribunal emphasized that once concessions are made and verified, the department cannot subsequently challenge the same. The appeal was found devoid of merit, with the cross objection deemed unnecessary as no substantive grievance existed against the original order. The decision affirmed procedural fairness in tax assessment proceedings.
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