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 held that the cessation of liability for a Rs. 4.80 crores deposit cannot be automatically inferred from Kamat Hotels' accounting actions. The tribunal found no basis for the lower authorities' observations and determined that the liability's quantification depends on the arbitrator's award. Regarding notional rent for property used by LIHS without consideration, the tribunal rejected the Assessing Officer's computation, noting that such notional income cannot be actually applied or accumulated for trust purposes. The tribunal directed deletion of both the liability addition and notional rent calculation, emphasizing that any potential violation under section 13(1)(c) read with section 13(1)(b) would only result in denial of benefits to the extent of diverted income.
ITAT held that the cessation of liability for a Rs. 4.80 crores deposit cannot be automatically inferred from Kamat Hotels' accounting actions. The tribunal found no basis for the lower authorities' observations and determined that the liability's quantification depends on the arbitrator's award. Regarding notional rent for property used by LIHS without consideration, the tribunal rejected the Assessing Officer's computation, noting that such notional income cannot be actually applied or accumulated for trust purposes. The tribunal directed deletion of both the liability addition and notional rent calculation, emphasizing that any potential violation under section 13(1)(c) read with section 13(1)(b) would only result in denial of benefits to the extent of diverted income.
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