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 dismissed the Revenue's appeals challenging the assessee bank's treatment of amortization of premium on HTM securities, holding it appropriate to amortize over the holding period in line with RBI guidelines. Disallowances relating to depreciation on investments, venture capital fund investments, and MTM derivatives were rejected, reaffirming prior Tribunal and Supreme Court precedents that found no escapement of income. The disallowance of inter-office adjustments was also dismissed, recognizing these as reconciled internal entries. Additions under section 14A read with Rule 8D concerning exempt income were negated following Delhi High Court rulings. Depreciation on goodwill was allowed as an intangible asset under section 32(1). Contributions to the pension fund were upheld as deductible business expenses under section 43B. Finally, the claim under section 36(1)(viii) for advances granted for eligible business purposes was allowed subject to quantification by the AO as directed by the CIT(A).
The ITAT dismissed the Revenue's appeals challenging the assessee bank's treatment of amortization of premium on HTM securities, holding it appropriate to amortize over the holding period in line with RBI guidelines. Disallowances relating to depreciation on investments, venture capital fund investments, and MTM derivatives were rejected, reaffirming prior Tribunal and Supreme Court precedents that found no escapement of income. The disallowance of inter-office adjustments was also dismissed, recognizing these as reconciled internal entries. Additions under section 14A read with Rule 8D concerning exempt income were negated following Delhi High Court rulings. Depreciation on goodwill was allowed as an intangible asset under section 32(1). Contributions to the pension fund were upheld as deductible business expenses under section 43B. Finally, the claim under section 36(1)(viii) for advances granted for eligible business purposes was allowed subject to quantification by the AO as directed by the CIT(A).
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