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 partly allowed revenue's appeal in tax assessment matter. Regarding addition under section 56(2)(x) for property valuation, ITAT upheld CIT(A)'s deletion following precedent where detailed valuation considered industrial NA land characteristics and stamp duty authority rules. For cash advance on Hundi, ITAT sustained CIT(A)'s deletion finding no evidence that Rs. 26 lakh exceeded documented Rs. 25 lakh loan paid through banking channels. However, ITAT reversed CIT(A) on interest receivable from advances, holding accrued interest must be added to total income since assessee admitted giving loan. For agricultural income classification, ITAT modified CIT(A)'s complete deletion, allowing Rs. 75,000 as reasonable agricultural income from 4.6 hectares but treating balance Rs. 1,01,015 as income from other sources due to insufficient cultivation proof.
ITAT partly allowed revenue's appeal in tax assessment matter. Regarding addition under section 56(2)(x) for property valuation, ITAT upheld CIT(A)'s deletion following precedent where detailed valuation considered industrial NA land characteristics and stamp duty authority rules. For cash advance on Hundi, ITAT sustained CIT(A)'s deletion finding no evidence that Rs. 26 lakh exceeded documented Rs. 25 lakh loan paid through banking channels. However, ITAT reversed CIT(A) on interest receivable from advances, holding accrued interest must be added to total income since assessee admitted giving loan. For agricultural income classification, ITAT modified CIT(A)'s complete deletion, allowing Rs. 75,000 as reasonable agricultural income from 4.6 hectares but treating balance Rs. 1,01,015 as income from other sources due to insufficient cultivation proof.
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