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 determined that a company engaged in manufacturing, incurring expenditure on scientific research and in-house R&D facility approved by the competent authority, is eligible for a 200% deduction under Section 35(2AB)(1). The court rejected the argument of "work-in-progress" as a disqualifying factor, noting the statutory provision only speaks of "expenditure" without distinguishing between completed and ongoing research. The petitioner was entitled to claim benefits for the actual year of expenditure incurrence, particularly given the reliance on prior advisory guidance. The court found in favor of the petitioner, allowing the deduction claim for scientific research expenditure.
HC determined that a company engaged in manufacturing, incurring expenditure on scientific research and in-house R&D facility approved by the competent authority, is eligible for a 200% deduction under Section 35(2AB)(1). The court rejected the argument of "work-in-progress" as a disqualifying factor, noting the statutory provision only speaks of "expenditure" without distinguishing between completed and ongoing research. The petitioner was entitled to claim benefits for the actual year of expenditure incurrence, particularly given the reliance on prior advisory guidance. The court found in favor of the petitioner, allowing the deduction claim for scientific research expenditure.
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