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 ruled on multiple taxation issues involving unexplained cash deposits during demonetization. The tribunal sustained addition u/s 69A regarding cash deposits, finding the assessee's explanations unconvincing. Bad debt claims were partially allowed under section 36(1)(vii). The tribunal rejected the assessee's books of accounts and applied a minimal gross profit percentage of 0.1%. Notional commission additions were deleted. Regarding section 115BBE, the tribunal followed precedent limiting 60% tax rate to transactions from 01.04.2017 onwards, thereby restricting tax to 30% for earlier periods. Overall, the decision partially favored the assessee while upholding significant tax adjustments related to unexplained cash deposits during demonetization.
ITAT ruled on multiple taxation issues involving unexplained cash deposits during demonetization. The tribunal sustained addition u/s 69A regarding cash deposits, finding the assessee's explanations unconvincing. Bad debt claims were partially allowed under section 36(1)(vii). The tribunal rejected the assessee's books of accounts and applied a minimal gross profit percentage of 0.1%. Notional commission additions were deleted. Regarding section 115BBE, the tribunal followed precedent limiting 60% tax rate to transactions from 01.04.2017 onwards, thereby restricting tax to 30% for earlier periods. Overall, the decision partially favored the assessee while upholding significant tax adjustments related to unexplained cash deposits during demonetization.
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