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 for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
ITAT ruled on multiple taxation issues for the assessee engaged in software development. The tribunal partially allowed the assessee's appeals, addressing key points: (1) computers used for software production qualify as plant and machinery eligible for additional depreciation under Section 32(1)(iia), (2) investment allowances under Section 32AC are permissible for computers used in software development, not administrative purposes, (3) suo-moto disallowance under Section 14A was accepted, (4) foreign tax deduction was allowed following precedent, and (5) MAT credit issue was remanded to Assessing Officer for fresh adjudication. The appeals were predominantly decided in favor of the assessee, with directions for detailed verification by the AO.
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