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 two key tax issues involving expense disallowance. Regarding bonus expenses under Section 43B, the tribunal directed the Jurisdictional Assessment Officer to allow deductions upon verification of supporting documentary evidence. Concerning interest payments under the MSMED Act, the tribunal found that the CPC's disallowance constituted an improper double disallowance, as the assessee had already self-disallowed the amounts during return filing. The tribunal restored the matter to the assessment officer for appropriate reconsideration, effectively allowing the ground for statistical purposes and preventing redundant tax treatment.
The ITAT addressed two key tax issues involving expense disallowance. Regarding bonus expenses under Section 43B, the tribunal directed the Jurisdictional Assessment Officer to allow deductions upon verification of supporting documentary evidence. Concerning interest payments under the MSMED Act, the tribunal found that the CPC's disallowance constituted an improper double disallowance, as the assessee had already self-disallowed the amounts during return filing. The tribunal restored the matter to the assessment officer for appropriate reconsideration, effectively allowing the ground for statistical purposes and preventing redundant tax treatment.
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