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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ITAT allowed assessee's appeal on multiple grounds of disallowance. The tribunal permitted ESOP expenses as deductible business expenditure under Section 37(1), upheld charges paid to stock exchanges as legitimate business expenses, and recognized settlement charges paid to SEBI as allowable expenditure. The tribunal consistently followed precedential decisions from previous cases involving similar technical violations and financial transactions. For gratuity payment reversal, ITAT directed the Assessing Officer to verify facts and provide appropriate relief, allowing the ground for statistical purposes with a requirement for the assessee to submit detailed documentation.
ITAT allowed assessee's appeal on multiple grounds of disallowance. The tribunal permitted ESOP expenses as deductible business expenditure under Section 37(1), upheld charges paid to stock exchanges as legitimate business expenses, and recognized settlement charges paid to SEBI as allowable expenditure. The tribunal consistently followed precedential decisions from previous cases involving similar technical violations and financial transactions. For gratuity payment reversal, ITAT directed the Assessing Officer to verify facts and provide appropriate relief, allowing the ground for statistical purposes with a requirement for the assessee to submit detailed documentation.
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