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 regarding disallowance under section 36(1)(iii) for interest-free advances to sister concern. Assessee company provided interest-free loan to sister concern while claiming interest deduction on secured loans from banks and financial institutions. CIT(A) deleted additions after examining remand report, finding no evidence that advances were made for non-business purposes. CIT(A) noted investee company regularly paid advance tax with effective tax rate exceeding assessee's rate. ITAT upheld CIT(A)'s decision, concluding the issue was examined correctly and additions were rightly deleted, establishing commercial expediency justified the interest-free advances despite simultaneous borrowing costs.
ITAT dismissed revenue's appeal regarding disallowance under section 36(1)(iii) for interest-free advances to sister concern. Assessee company provided interest-free loan to sister concern while claiming interest deduction on secured loans from banks and financial institutions. CIT(A) deleted additions after examining remand report, finding no evidence that advances were made for non-business purposes. CIT(A) noted investee company regularly paid advance tax with effective tax rate exceeding assessee's rate. ITAT upheld CIT(A)'s decision, concluding the issue was examined correctly and additions were rightly deleted, establishing commercial expediency justified the interest-free advances despite simultaneous borrowing costs.
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