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 upheld CIT(A)'s deletion of disallowances for material and plot development expenses totaling Rs. 4,51,00,181, finding that common expenditure was legitimately borne by RNTC under development agreement, while assessee incurred specific plot development costs recoverable at Rs. 100 per sq. meter from plot owners. However, ITAT reversed CIT(A) regarding commission/brokerage expense disallowance, ruling that since land ownership vested with RNTC under development agreement, commission for individual plot sales should be borne by RNTC, not assessee. AO's action disallowing commission expense and reducing capitalized closing stock was upheld. Revenue's appeal partially allowed.
ITAT upheld CIT(A)'s deletion of disallowances for material and plot development expenses totaling Rs. 4,51,00,181, finding that common expenditure was legitimately borne by RNTC under development agreement, while assessee incurred specific plot development costs recoverable at Rs. 100 per sq. meter from plot owners. However, ITAT reversed CIT(A) regarding commission/brokerage expense disallowance, ruling that since land ownership vested with RNTC under development agreement, commission for individual plot sales should be borne by RNTC, not assessee. AO's action disallowing commission expense and reducing capitalized closing stock was upheld. Revenue's appeal partially allowed.
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