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 a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
ITAT adjudicated a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
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