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 multiple tax-related issues for the assessee. The tribunal disallowed leave encashment provision under section 43B(f), holding that if provision is made in an earlier year and not paid by the income tax return filing due date, deduction cannot be claimed. For warranty provision and software maintenance charges, the tribunal largely ruled in favor of the assessee, directing the Assessing Officer to follow previous coordinate bench decisions. Regarding liquidated damages, the tribunal allowed claims for TATA AIG agreement and remanded the BSNL agreement issue back to the Assessing Officer for further verification, maintaining a nuanced approach to the assessee's tax claims across different contractual contexts.
ITAT adjudicated multiple tax-related issues for the assessee. The tribunal disallowed leave encashment provision under section 43B(f), holding that if provision is made in an earlier year and not paid by the income tax return filing due date, deduction cannot be claimed. For warranty provision and software maintenance charges, the tribunal largely ruled in favor of the assessee, directing the Assessing Officer to follow previous coordinate bench decisions. Regarding liquidated damages, the tribunal allowed claims for TATA AIG agreement and remanded the BSNL agreement issue back to the Assessing Officer for further verification, maintaining a nuanced approach to the assessee's tax claims across different contractual contexts.
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