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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HC affirmed ITAT's findings regarding development expenditures for land levelling, road construction, compound wall repair, and well restoration. The court validated the assessee's claims based on physical verification, contractor payment records, and tax deduction evidence. Contractors confirmed work completion and receipt of payments through proper channels. Brokerage expenses were also substantiated by broker's confirmation letter and purchaser's sworn statement. The HC found no grounds to interfere with ITAT's concurrent findings, answering all substantial questions of law in the assessee's favor and upholding the claimed development and brokerage expenses.
HC affirmed ITAT's findings regarding development expenditures for land levelling, road construction, compound wall repair, and well restoration. The court validated the assessee's claims based on physical verification, contractor payment records, and tax deduction evidence. Contractors confirmed work completion and receipt of payments through proper channels. Brokerage expenses were also substantiated by broker's confirmation letter and purchaser's sworn statement. The HC found no grounds to interfere with ITAT's concurrent findings, answering all substantial questions of law in the assessee's favor and upholding the claimed development and brokerage expenses.
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