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 quashed assessment orders under section 153C for assessment years 2016-17 and 2017-18, ruling that the Assessing Officer lacked jurisdiction over the assessee whose documents were found during search operations. The tribunal found that satisfaction regarding the searched person was recorded on 06.09.2018, while satisfaction for the other person was recorded on 03.09.2018, creating jurisdictional deficiency. The satisfaction dated 03.09.2018 was deemed legally invalid without proper foundational satisfaction from the searched person's AO. Regarding undisclosed business income from on-money receipts on property sales, ITAT directed estimation of 25% profit on total gross receipts instead of treating entire amounts as unaccounted sales, recognizing legitimate business expenditure against unaccounted receipts and deleting balance additions.
ITAT quashed assessment orders under section 153C for assessment years 2016-17 and 2017-18, ruling that the Assessing Officer lacked jurisdiction over the assessee whose documents were found during search operations. The tribunal found that satisfaction regarding the searched person was recorded on 06.09.2018, while satisfaction for the other person was recorded on 03.09.2018, creating jurisdictional deficiency. The satisfaction dated 03.09.2018 was deemed legally invalid without proper foundational satisfaction from the searched person's AO. Regarding undisclosed business income from on-money receipts on property sales, ITAT directed estimation of 25% profit on total gross receipts instead of treating entire amounts as unaccounted sales, recognizing legitimate business expenditure against unaccounted receipts and deleting balance additions.
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