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 multiple taxation issues for the assessee. The tribunal partially allowed deductions under Section 80-IA against gross total income, not restricting it to business income, following Supreme Court precedent in Reliance Energy Limited. Club expenses were allowed based on consistent historical treatment. CSR donation deductions under Section 80G were upheld. The tribunal restored the weighted deduction claim under Section 35(2)(ab) to the AO for fresh consideration, providing an opportunity to submit Form 3CL. Disallowance under Section 14A was dismissed, and transfer pricing adjustments related to power transfer were evaluated based on arm's length pricing methodologies established in prior judicial interpretations.
The ITAT addressed multiple taxation issues for the assessee. The tribunal partially allowed deductions under Section 80-IA against gross total income, not restricting it to business income, following Supreme Court precedent in Reliance Energy Limited. Club expenses were allowed based on consistent historical treatment. CSR donation deductions under Section 80G were upheld. The tribunal restored the weighted deduction claim under Section 35(2)(ab) to the AO for fresh consideration, providing an opportunity to submit Form 3CL. Disallowance under Section 14A was dismissed, and transfer pricing adjustments related to power transfer were evaluated based on arm's length pricing methodologies established in prior judicial interpretations.
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