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 adjudicated two primary issues: (1) International transaction involving Standby Letter of Credit (SBLC) and (2) Deduction under Section 80G for charitable donation. In the SBLC matter, the Tribunal held that issuance of SBLC to Associated Enterprise can be subject to Arm's Length Price (ALP) tests, directing Assessing Officer to consider 0.5% rate instead of 1.3%. Regarding donation, the Tribunal restored the matter to Assessing Officer, providing opportunity to re-examine the receipt's authenticity and accounting period, with liberty to allow Section 80G deduction if the assessee satisfactorily demonstrates the trust's proper accounting of the donated funds.
ITAT adjudicated two primary issues: (1) International transaction involving Standby Letter of Credit (SBLC) and (2) Deduction under Section 80G for charitable donation. In the SBLC matter, the Tribunal held that issuance of SBLC to Associated Enterprise can be subject to Arm's Length Price (ALP) tests, directing Assessing Officer to consider 0.5% rate instead of 1.3%. Regarding donation, the Tribunal restored the matter to Assessing Officer, providing opportunity to re-examine the receipt's authenticity and accounting period, with liberty to allow Section 80G deduction if the assessee satisfactorily demonstrates the trust's proper accounting of the donated funds.
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