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 protective additions under section 68. The assessing officer alleged the assessee company acted as a conduit providing accommodation entries to beneficiaries and earned unaccounted commission. Following the precedent in Holeon Traders Pvt. Ltd., ITAT upheld deletion of protective additions made against the assessee. Regarding unaccounted commission additions, ITAT noted that while the coordinate bench initially upheld commission income additions deleted by CIT(A), a subsequent corrigendum dated 31/07/2023 clarified that CIT(A) was correct in deleting the commission income additions. Consequently, both grounds of revenue's appeal were dismissed, confirming deletion of additions made under section 68 for accommodation entries and unaccounted commission income in the assessee company's hands.
ITAT dismissed revenue's appeal regarding protective additions under section 68. The assessing officer alleged the assessee company acted as a conduit providing accommodation entries to beneficiaries and earned unaccounted commission. Following the precedent in Holeon Traders Pvt. Ltd., ITAT upheld deletion of protective additions made against the assessee. Regarding unaccounted commission additions, ITAT noted that while the coordinate bench initially upheld commission income additions deleted by CIT(A), a subsequent corrigendum dated 31/07/2023 clarified that CIT(A) was correct in deleting the commission income additions. Consequently, both grounds of revenue's appeal were dismissed, confirming deletion of additions made under section 68 for accommodation entries and unaccounted commission income in the assessee company's hands.
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