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 upheld ITAT's decision allowing depreciation on beverages division assets under Section 32, ruling that machinery kept ready for commercial production but unused due to public agitation beyond assessee's control qualifies for depreciation. Court held assets became part of block assets in ongoing business, making depreciation allowable on entire block regardless of individual asset usage. HC also allowed expenditure deduction for cane price differential, finding government orders were received in May-June 2005, making expenditure crystallize in relevant assessment year. Court permitted deduction of excess payments to farmers treated as goodwill, recognizing legitimate business expenditure for uninterrupted sugarcane supply. Consequently, book profit computation under Section 115JB was adjusted favorably for assessee across all disputed issues.
HC upheld ITAT's decision allowing depreciation on beverages division assets under Section 32, ruling that machinery kept ready for commercial production but unused due to public agitation beyond assessee's control qualifies for depreciation. Court held assets became part of block assets in ongoing business, making depreciation allowable on entire block regardless of individual asset usage. HC also allowed expenditure deduction for cane price differential, finding government orders were received in May-June 2005, making expenditure crystallize in relevant assessment year. Court permitted deduction of excess payments to farmers treated as goodwill, recognizing legitimate business expenditure for uninterrupted sugarcane supply. Consequently, book profit computation under Section 115JB was adjusted favorably for assessee across all disputed issues.
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