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 assessee's appeal, holding that license fees from commercial spaces in mall/warehouse should be assessed under house property income, consistent with previous years' treatment. The tribunal directed the Assessing Officer to assess income under house property and delete the addition to total income. Additionally, the ITAT found the section 143(2) notice invalid due to non-compliance with CBDT instructions, rendering the entire assessment proceeding void. The decision upheld the principle of maintaining consistent income classification across assessment years and emphasized procedural compliance in tax proceedings.
ITAT allowed the assessee's appeal, holding that license fees from commercial spaces in mall/warehouse should be assessed under house property income, consistent with previous years' treatment. The tribunal directed the Assessing Officer to assess income under house property and delete the addition to total income. Additionally, the ITAT found the section 143(2) notice invalid due to non-compliance with CBDT instructions, rendering the entire assessment proceeding void. The decision upheld the principle of maintaining consistent income classification across assessment years and emphasized procedural compliance in tax proceedings.
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