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 allowed the taxpayer's appeal, reversing the disallowance of expenses under Section 37(1). Despite vendors not being GST-registered, the tribunal found the expenses genuine, as payments were made through banking channels with TDS deducted. The Assessing Officer's rationale of disallowing expenses solely on GST registration status was deemed incorrect. The tribunal emphasized that the Income Tax Act does not mandate expenses be incurred only with GST-registered entities. By examining submitted invoices and payment evidence, the tribunal concluded the expenses were legitimate and directed the AO to delete the addition, thereby providing relief to the assessee.
ITAT allowed the taxpayer's appeal, reversing the disallowance of expenses under Section 37(1). Despite vendors not being GST-registered, the tribunal found the expenses genuine, as payments were made through banking channels with TDS deducted. The Assessing Officer's rationale of disallowing expenses solely on GST registration status was deemed incorrect. The tribunal emphasized that the Income Tax Act does not mandate expenses be incurred only with GST-registered entities. By examining submitted invoices and payment evidence, the tribunal concluded the expenses were legitimate and directed the AO to delete the addition, thereby providing relief to the assessee.
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