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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The ITAT partially allowed the taxpayer's appeal, reversing two significant disallowances while dismissing one ground. Regarding the Rs. 2,60,67,039 disallowance under section 43B, the tribunal held that since no GST deduction was claimed as operating expenses and no GST liability existed as of 31.3.2018, the disallowance based on an incorrect tax audit report was unjustified. For the section 36(1)(va) disallowance concerning delayed PF deposits, the tribunal ruled that depositing PF contributions on the next working day after the due date fell on Sunday constituted timely payment under legal principles governing office closures. The ground regarding erroneous basic tax rate claim was dismissed as not pressed by the taxpayer's representative during proceedings.
The ITAT partially allowed the taxpayer's appeal, reversing two significant disallowances while dismissing one ground. Regarding the Rs. 2,60,67,039 disallowance under section 43B, the tribunal held that since no GST deduction was claimed as operating expenses and no GST liability existed as of 31.3.2018, the disallowance based on an incorrect tax audit report was unjustified. For the section 36(1)(va) disallowance concerning delayed PF deposits, the tribunal ruled that depositing PF contributions on the next working day after the due date fell on Sunday constituted timely payment under legal principles governing office closures. The ground regarding erroneous basic tax rate claim was dismissed as not pressed by the taxpayer's representative during proceedings.
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