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 analyzed income accrual under mercantile accounting system, addressing electricity charge recoveries. The tribunal found that the assessee had correctly adjusted receivables from the state electricity board across multiple assessment years without double taxation. The tribunal determined that adding the disputed amount would constitute duplicate taxation, as the income was already recognized in subsequent years consistent with Supreme Court directives. Consequently, the tribunal granted relief to the assessee, concluding no substantial legal question existed in the appeal.
HC analyzed income accrual under mercantile accounting system, addressing electricity charge recoveries. The tribunal found that the assessee had correctly adjusted receivables from the state electricity board across multiple assessment years without double taxation. The tribunal determined that adding the disputed amount would constitute duplicate taxation, as the income was already recognized in subsequent years consistent with Supreme Court directives. Consequently, the tribunal granted relief to the assessee, concluding no substantial legal question existed in the appeal.
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