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 partially allows appeal, directing AO to re-examine multiple tax issues. Key holdings include: (1) Government grant of Rs. 150 crores transferred to implementing agency is not taxable income; (2) disallowed interest expenditure of Rs. 547.50 crores requires fresh assessment considering accounting treatment; (3) unexplained investment provisions under section 69 incorrectly invoked against state undertaking; (4) unrecorded rental income from National Housing Board to be verified with already accounted amounts; (5) brought forward business loss set-off to be re-examined; and (6) interest under sections 234A and 234B to be recomputed based on final income determination. Matter substantially restored to Assessing Officer for detailed re-evaluation.
ITAT partially allows appeal, directing AO to re-examine multiple tax issues. Key holdings include: (1) Government grant of Rs. 150 crores transferred to implementing agency is not taxable income; (2) disallowed interest expenditure of Rs. 547.50 crores requires fresh assessment considering accounting treatment; (3) unexplained investment provisions under section 69 incorrectly invoked against state undertaking; (4) unrecorded rental income from National Housing Board to be verified with already accounted amounts; (5) brought forward business loss set-off to be re-examined; and (6) interest under sections 234A and 234B to be recomputed based on final income determination. Matter substantially restored to Assessing Officer for detailed re-evaluation.
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