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 two key tax issues involving a State Government undertaking. First, the tribunal upheld disallowance of guarantee commission paid to Kerala State Government under section 40(a)(iib), aligning with Supreme Court precedent that fees paid by State Government undertakings are non-deductible. Second, regarding provision for bad and doubtful debts, the tribunal remanded the matter to the Assessing Officer for reconsideration, directing a detailed examination of debt write-offs consistent with Supreme Court guidelines in Vijaya Bank case. The first ground was dismissed, while the second ground was partly allowed for statistical purposes, mandating a fresh assessment of deductibility criteria.
ITAT adjudicated two key tax issues involving a State Government undertaking. First, the tribunal upheld disallowance of guarantee commission paid to Kerala State Government under section 40(a)(iib), aligning with Supreme Court precedent that fees paid by State Government undertakings are non-deductible. Second, regarding provision for bad and doubtful debts, the tribunal remanded the matter to the Assessing Officer for reconsideration, directing a detailed examination of debt write-offs consistent with Supreme Court guidelines in Vijaya Bank case. The first ground was dismissed, while the second ground was partly allowed for statistical purposes, mandating a fresh assessment of deductibility criteria.
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