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 held that the disallowance of the deduction claimed under section 80P during assessment year 2018-19 was improper. The power conferred on the Assessing Officer by the Finance Act, 2021 to disallow deductions under Chapter VIA while processing returns under section 143(1) is applicable only from assessment year 2021-22 onwards. Consequently, the CPC lacked jurisdiction to disallow the deduction under section 80P for the relevant earlier year during return processing. The tribunal therefore allowed the assessee's appeal, restoring the deduction claimed under section 80P for AY 2018-19.
The ITAT held that the disallowance of the deduction claimed under section 80P during assessment year 2018-19 was improper. The power conferred on the Assessing Officer by the Finance Act, 2021 to disallow deductions under Chapter VIA while processing returns under section 143(1) is applicable only from assessment year 2021-22 onwards. Consequently, the CPC lacked jurisdiction to disallow the deduction under section 80P for the relevant earlier year during return processing. The tribunal therefore allowed the assessee's appeal, restoring the deduction claimed under section 80P for AY 2018-19.
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