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 held that additional income declared by assessee during survey u/s 133A relating to unexplained stock should be taxed as business income at normal rates rather than under sections 69/69C read with section 115BBE. The tribunal found that since assessee's sole source of income was retail shoe trading with no other business activities discovered during survey or subsequently, the excess stock constituted business income. Following precedent in Bajargan Traders, ITAT upheld CIT(A)/NFAC order directing assessment officer to treat additional income as normal business income instead of applying penal provisions. Revenue's appeal was dismissed, confirming taxation at regular business income rates rather than higher rates under unexplained investment provisions.
ITAT held that additional income declared by assessee during survey u/s 133A relating to unexplained stock should be taxed as business income at normal rates rather than under sections 69/69C read with section 115BBE. The tribunal found that since assessee's sole source of income was retail shoe trading with no other business activities discovered during survey or subsequently, the excess stock constituted business income. Following precedent in Bajargan Traders, ITAT upheld CIT(A)/NFAC order directing assessment officer to treat additional income as normal business income instead of applying penal provisions. Revenue's appeal was dismissed, confirming taxation at regular business income rates rather than higher rates under unexplained investment provisions.
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