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 deduction of employees' superannuation fund contributions under section 36(1)(va). The assessee made payments after the scheme's prescribed due date but before the return filing due date under section 139(1). The tribunal upheld CIT(A)'s finding that contributions deposited before section 139(1) due date qualify for deduction, provided the superannuation fund maintains approved status. CIT(A) properly directed the assessing officer to verify the fund's approval status and allow the claim accordingly. The tribunal found no infirmity in CIT(A)'s order and deemed the directions fair and reasonable. Appeal allowed for statistical purposes.
ITAT allowed the assessee's appeal regarding deduction of employees' superannuation fund contributions under section 36(1)(va). The assessee made payments after the scheme's prescribed due date but before the return filing due date under section 139(1). The tribunal upheld CIT(A)'s finding that contributions deposited before section 139(1) due date qualify for deduction, provided the superannuation fund maintains approved status. CIT(A) properly directed the assessing officer to verify the fund's approval status and allow the claim accordingly. The tribunal found no infirmity in CIT(A)'s order and deemed the directions fair and reasonable. Appeal allowed for statistical purposes.
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