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 a tax regime dispute involving a taxpayer's revised return. The tribunal held that since the assessee was ultimately taxed under the old tax regime, they are entitled to claim deductions under section 115BAC(2) and (3). The appellate tribunal directed the Assessing Officer to reinstate the originally processed deductions that were subsequently denied when the taxpayer attempted to switch to the new tax regime. The tribunal's ruling ensures the taxpayer can avail of the deductions available in the original tax regime, effectively protecting the taxpayer's right to optimal tax treatment.
ITAT adjudicated a tax regime dispute involving a taxpayer's revised return. The tribunal held that since the assessee was ultimately taxed under the old tax regime, they are entitled to claim deductions under section 115BAC(2) and (3). The appellate tribunal directed the Assessing Officer to reinstate the originally processed deductions that were subsequently denied when the taxpayer attempted to switch to the new tax regime. The tribunal's ruling ensures the taxpayer can avail of the deductions available in the original tax regime, effectively protecting the taxpayer's right to optimal tax treatment.
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