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 partially allowed the assessee's appeal regarding disallowances under sections 37 and 36(1)(va). The tribunal deleted additions relating to customs duty fines and penalties, ruling these were compensatory rather than penal in nature, following precedent in Akshay Khetterpal vs. ACIT. However, regarding Provident Fund contribution disallowances, the tribunal applied Supreme Court precedent in Checkmate Services Pvt. Ltd., confirming that payments made beyond statutory due dates are not deductible. The PF matter was remitted to the Assessing Officer for fresh consideration to verify actual payment dates, with directions to allow only contributions made before the prescribed due date under relevant Acts.
ITAT partially allowed the assessee's appeal regarding disallowances under sections 37 and 36(1)(va). The tribunal deleted additions relating to customs duty fines and penalties, ruling these were compensatory rather than penal in nature, following precedent in Akshay Khetterpal vs. ACIT. However, regarding Provident Fund contribution disallowances, the tribunal applied Supreme Court precedent in Checkmate Services Pvt. Ltd., confirming that payments made beyond statutory due dates are not deductible. The PF matter was remitted to the Assessing Officer for fresh consideration to verify actual payment dates, with directions to allow only contributions made before the prescribed due date under relevant Acts.
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