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 allowed the assessee's appeal in part by directing the AO to restrict the disallowance under section 14A read with Rule 8D to the exempt dividend income of Rs. 15,40,235, affirming that the assessed income may be lower than the returned income. The claim for deduction of maintenance expenses was restored to the AO for fresh adjudication due to lack of factual examination by lower authorities. However, the Tribunal dismissed the assessee's claim for deduction of interest on delayed TDS payment under section 37(1), holding that such interest is not an allowable business expenditure as it arises from non-compliance with statutory requirements and is not incidental to business operations. Thus, grounds one and two were allowed (with the second for statistical purposes), while ground three was dismissed.
The ITAT allowed the assessee's appeal in part by directing the AO to restrict the disallowance under section 14A read with Rule 8D to the exempt dividend income of Rs. 15,40,235, affirming that the assessed income may be lower than the returned income. The claim for deduction of maintenance expenses was restored to the AO for fresh adjudication due to lack of factual examination by lower authorities. However, the Tribunal dismissed the assessee's claim for deduction of interest on delayed TDS payment under section 37(1), holding that such interest is not an allowable business expenditure as it arises from non-compliance with statutory requirements and is not incidental to business operations. Thus, grounds one and two were allowed (with the second for statistical purposes), while ground three was dismissed.
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