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 partially allowed the assessee's appeal, directing deletion of several additions and modifications to income calculations. Key outcomes include: (1) commission income restricted to Rs. 7,595 at 0.15% rate, (2) unsecured loan addition under Section 68 deleted based on supporting documentation, (3) surrendered income allowed at normal tax rates, (4) notice under Section 148 quashed due to invalid approval, and (5) bank account credit from share transfer recognized as explained income. The Tribunal found insufficient evidence by the AO to substantiate unexplained income claims and systematically set aside most additions, providing relief to the assessee across multiple contested income components.
The ITAT partially allowed the assessee's appeal, directing deletion of several additions and modifications to income calculations. Key outcomes include: (1) commission income restricted to Rs. 7,595 at 0.15% rate, (2) unsecured loan addition under Section 68 deleted based on supporting documentation, (3) surrendered income allowed at normal tax rates, (4) notice under Section 148 quashed due to invalid approval, and (5) bank account credit from share transfer recognized as explained income. The Tribunal found insufficient evidence by the AO to substantiate unexplained income claims and systematically set aside most additions, providing relief to the assessee across multiple contested income components.
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