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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The ITAT addressed two key tax issues: (1) interest received on land acquisition compensation under Section 28 of the Land Acquisition Act, 1894, and (2) deduction claimed under Section 80GGB for political contributions. The tribunal remanded both matters to the Assessing Officer (AO) for detailed factual verification and re-computation. The first issue requires examination of the nature and computation of interest on enhanced compensation, while the second issue involves verifying political contributions and recalculating permissible deductions in accordance with prevailing legal provisions. Both grounds were allowed for statistical purposes, directing the AO to conduct a comprehensive review and reassessment.
The ITAT addressed two key tax issues: (1) interest received on land acquisition compensation under Section 28 of the Land Acquisition Act, 1894, and (2) deduction claimed under Section 80GGB for political contributions. The tribunal remanded both matters to the Assessing Officer (AO) for detailed factual verification and re-computation. The first issue requires examination of the nature and computation of interest on enhanced compensation, while the second issue involves verifying political contributions and recalculating permissible deductions in accordance with prevailing legal provisions. Both grounds were allowed for statistical purposes, directing the AO to conduct a comprehensive review and reassessment.
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