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 appeal and deleted the disallowance of interest expenses under Section 40(a)(ia). The Assessing Officer erroneously disallowed expenses that were not claimed against business income but against rental income. The appellant had returned business income on presumptive basis under Section 44AD and claimed the disputed interest expenses against separate rental income. ITAT held that Section 40(a)(ia) provisions under Chapter IV-D apply only to computation of income from business and profession, not rental income. The disallowance was deemed unjustified and legally unsustainable. Consequently, the penalty under Section 271(1)(c) imposed in relation to the disallowance was also deleted.
ITAT allowed the appeal and deleted the disallowance of interest expenses under Section 40(a)(ia). The Assessing Officer erroneously disallowed expenses that were not claimed against business income but against rental income. The appellant had returned business income on presumptive basis under Section 44AD and claimed the disputed interest expenses against separate rental income. ITAT held that Section 40(a)(ia) provisions under Chapter IV-D apply only to computation of income from business and profession, not rental income. The disallowance was deemed unjustified and legally unsustainable. Consequently, the penalty under Section 271(1)(c) imposed in relation to the disallowance was also deleted.
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