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 dismissed Revenue's appeal challenging CIT(A)'s deletions across multiple grounds. Regarding Section 68 additions on current liabilities and loans/advances, ITAT held these represented bona fide deposits and core cooperative society operations, not unexplained credits, following precedent from assessee's own case for AY 2018-19. Personal expenditure and Section 40A(7) disallowances were confirmed as deleted since amounts were already disallowed in computation, making AO's additions duplicative. Section 80P(2)(a)(i) deduction denial was reversed as interest income from cooperative banks qualified under Section 80P(2)(d) per established precedents. CIT(A)'s consideration of explanations from existing financial records did not violate Rule 46A, as no new documentary evidence was introduced and first appellate authority possesses broad inquiry powers under Section 250(4).
ITAT dismissed Revenue's appeal challenging CIT(A)'s deletions across multiple grounds. Regarding Section 68 additions on current liabilities and loans/advances, ITAT held these represented bona fide deposits and core cooperative society operations, not unexplained credits, following precedent from assessee's own case for AY 2018-19. Personal expenditure and Section 40A(7) disallowances were confirmed as deleted since amounts were already disallowed in computation, making AO's additions duplicative. Section 80P(2)(a)(i) deduction denial was reversed as interest income from cooperative banks qualified under Section 80P(2)(d) per established precedents. CIT(A)'s consideration of explanations from existing financial records did not violate Rule 46A, as no new documentary evidence was introduced and first appellate authority possesses broad inquiry powers under Section 250(4).
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