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 upheld the deletion of transfer pricing adjustments related to power and steam transfers between eligible and non-eligible units under section 80IA, affirming the CIT(A)'s order. It directed the AO to verify additional evidence and claims for revised deductions under section 80IA concerning steam transfers. Disallowances under section 14A read with Rule 8D were deleted, given sufficient interest-free funds, and no addition was allowed in book profits under section 115JB. The AO was directed to re-compute the arm's length price for hybrid seed sales after including specified comparables. Issues of foreign tax credit delay, interest disallowance, and discrepancies in sales reporting were remitted to AO for verification. Double additions and disallowances by CPC were set aside. The AO was further directed to allow deductions under section 80IA as per Form 10CCB and grant foreign tax credit under section 90. Other disputed claims were either dismissed or remanded for fresh adjudication in accordance with law.
The ITAT upheld the deletion of transfer pricing adjustments related to power and steam transfers between eligible and non-eligible units under section 80IA, affirming the CIT(A)'s order. It directed the AO to verify additional evidence and claims for revised deductions under section 80IA concerning steam transfers. Disallowances under section 14A read with Rule 8D were deleted, given sufficient interest-free funds, and no addition was allowed in book profits under section 115JB. The AO was directed to re-compute the arm's length price for hybrid seed sales after including specified comparables. Issues of foreign tax credit delay, interest disallowance, and discrepancies in sales reporting were remitted to AO for verification. Double additions and disallowances by CPC were set aside. The AO was further directed to allow deductions under section 80IA as per Form 10CCB and grant foreign tax credit under section 90. Other disputed claims were either dismissed or remanded for fresh adjudication in accordance with law.
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