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 the assessee's appeal regarding unexplained cash credits under section 68. The tribunal held that when assessee provides creditor details including names, addresses, and registration numbers, burden shifts to Revenue to establish lack of creditworthiness. AO failed to conduct proper inquiry or make assessments against lender companies under section 69. Mere non-compliance with summons insufficient for adverse inference. Addition on sundry creditors deleted as assessee was registered charitable institution under sections 12AA and 80G, and supplies were not disputed. Regarding depreciation on new assets, ITAT directed AO to allow depreciation if assets were ready for use at year-end, partially allowing the ground for statistical purposes.
ITAT allowed the assessee's appeal regarding unexplained cash credits under section 68. The tribunal held that when assessee provides creditor details including names, addresses, and registration numbers, burden shifts to Revenue to establish lack of creditworthiness. AO failed to conduct proper inquiry or make assessments against lender companies under section 69. Mere non-compliance with summons insufficient for adverse inference. Addition on sundry creditors deleted as assessee was registered charitable institution under sections 12AA and 80G, and supplies were not disputed. Regarding depreciation on new assets, ITAT directed AO to allow depreciation if assets were ready for use at year-end, partially allowing the ground for statistical purposes.
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