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 partial appeal regarding tax depreciation and expenditure deductions. The tribunal permitted depreciation on non-compete agreement payment as an intangible asset under Section 32(1)(ii), allowing the appellant's claim. Disallowance under Section 14A was set aside, finding the retrospective amendment inapplicable. Appeals related to rights issue expenditure and MAT credit were dismissed. The tribunal rejected disallowance of belated ESI and Labour Welfare Fund remittance, aligning with precedent judicial interpretation. Overall, the decision partially favored the appellant's tax treatment, providing nuanced interpretation of statutory provisions.
ITAT allowed partial appeal regarding tax depreciation and expenditure deductions. The tribunal permitted depreciation on non-compete agreement payment as an intangible asset under Section 32(1)(ii), allowing the appellant's claim. Disallowance under Section 14A was set aside, finding the retrospective amendment inapplicable. Appeals related to rights issue expenditure and MAT credit were dismissed. The tribunal rejected disallowance of belated ESI and Labour Welfare Fund remittance, aligning with precedent judicial interpretation. Overall, the decision partially favored the appellant's tax treatment, providing nuanced interpretation of statutory provisions.
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