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 regarding depreciation claim on intangible assets. The tribunal held that the assessee's depreciation claim on intangible assets under development was legally sustainable. The court emphasized that not every revenue loss constitutes prejudice to revenue interests. Citing SC precedents, the tribunal confirmed that when an AO adopts a permissible approach and takes a reasonable view, the assessment cannot be considered erroneous. The tribunal quashed the CIT's order under Section 263, ruling that the depreciation claim on goodwill was allowable and did not cause revenue prejudice. Consequently, the assessee's appeal grounds were fully allowed, maintaining the original depreciation claim.
ITAT adjudicated a tax dispute regarding depreciation claim on intangible assets. The tribunal held that the assessee's depreciation claim on intangible assets under development was legally sustainable. The court emphasized that not every revenue loss constitutes prejudice to revenue interests. Citing SC precedents, the tribunal confirmed that when an AO adopts a permissible approach and takes a reasonable view, the assessment cannot be considered erroneous. The tribunal quashed the CIT's order under Section 263, ruling that the depreciation claim on goodwill was allowable and did not cause revenue prejudice. Consequently, the assessee's appeal grounds were fully allowed, maintaining the original depreciation claim.
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