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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The ITAT quashed the revisionary order under section 263, upholding the assessment order under section 143(3) as neither erroneous nor prejudicial to Revenue. The PCIT failed to demonstrate any material difference in facts or law for AY 2020-21 compared to AY 2018-19 regarding foreign tax credit under section 90 for income from the Philippines branch. The AO's acceptance of reconciliation and evidence was sufficient application of mind. Additionally, the deduction under section 80G for donations qualifying under statutory criteria was rightly allowed despite CSR obligations, as section 37(1) Explanation 2 does not negate section 80G claims. Revisionary interference was thus unsustainable, and the appeal was allowed.
The ITAT quashed the revisionary order under section 263, upholding the assessment order under section 143(3) as neither erroneous nor prejudicial to Revenue. The PCIT failed to demonstrate any material difference in facts or law for AY 2020-21 compared to AY 2018-19 regarding foreign tax credit under section 90 for income from the Philippines branch. The AO's acceptance of reconciliation and evidence was sufficient application of mind. Additionally, the deduction under section 80G for donations qualifying under statutory criteria was rightly allowed despite CSR obligations, as section 37(1) Explanation 2 does not negate section 80G claims. Revisionary interference was thus unsustainable, and the appeal was allowed.
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