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 upheld the CIT(A)'s order with key findings: (1) Electronic evidence seized during search was admissible under Section 65B of Indian Evidence Act, (2) Cash receipts from property sales would be taxed only on profit element estimated at 12.5%, (3) For eight plots, matter was remanded to AO for reference to DVO under Section 43CA, (4) Unaccounted scrap sales addition of 20% was confirmed, (5) Bogus steel purchase addition limited to 17% profit element, (6) Salary disallowance to an employee was deleted due to lack of corroborative evidence, and (7) Disallowance under Sections 40A(3) and 37 was rejected as no substantive evidence supported the addition. Overall, most additions were either deleted or substantially reduced.
ITAT upheld the CIT(A)'s order with key findings: (1) Electronic evidence seized during search was admissible under Section 65B of Indian Evidence Act, (2) Cash receipts from property sales would be taxed only on profit element estimated at 12.5%, (3) For eight plots, matter was remanded to AO for reference to DVO under Section 43CA, (4) Unaccounted scrap sales addition of 20% was confirmed, (5) Bogus steel purchase addition limited to 17% profit element, (6) Salary disallowance to an employee was deleted due to lack of corroborative evidence, and (7) Disallowance under Sections 40A(3) and 37 was rejected as no substantive evidence supported the addition. Overall, most additions were either deleted or substantially reduced.
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