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 analyzed multiple taxation issues for a cooperative credit society. The tribunal partially allowed the appeal, directing: (1) deletion of additions under Section 68 due to lack of evidence regarding cash deposits, (2) deletion of disallowance of rental payments under Section 40A(3), (3) allowing deduction under Section 80P for member transactions, and (4) restoring certain issues like prior period expenses and bank account recoveries to Assessing Officer for de novo adjudication. The tribunal upheld disallowances related to standard asset provisions, gratuity provisions, and rejected assessee's contentions about special audit directions. Overall, the decision provided nuanced interpretations across various taxation aspects while maintaining procedural fairness.
ITAT analyzed multiple taxation issues for a cooperative credit society. The tribunal partially allowed the appeal, directing: (1) deletion of additions under Section 68 due to lack of evidence regarding cash deposits, (2) deletion of disallowance of rental payments under Section 40A(3), (3) allowing deduction under Section 80P for member transactions, and (4) restoring certain issues like prior period expenses and bank account recoveries to Assessing Officer for de novo adjudication. The tribunal upheld disallowances related to standard asset provisions, gratuity provisions, and rejected assessee's contentions about special audit directions. Overall, the decision provided nuanced interpretations across various taxation aspects while maintaining procedural fairness.
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