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 set aside the revision under section 263, holding that the PCIT erred in disallowing the deduction of tax on provisional expenses, as these provisions complied with the Mercantile System of Accounting mandated by the Income Tax Act and Companies Act. The tribunal noted that the provisions were reversed on the first day of the subsequent financial year, negating any tax deduction failure. Additionally, the ITAT upheld the depreciation claim on an intangible asset with a nil acquisition cost, ruling that the TDS paid on the premium became part of the block of assets and could not be separately disallowed. Consequently, the AO's disallowance of depreciation was quashed, and the appeal was allowed in favor of the assessee.
The ITAT set aside the revision under section 263, holding that the PCIT erred in disallowing the deduction of tax on provisional expenses, as these provisions complied with the Mercantile System of Accounting mandated by the Income Tax Act and Companies Act. The tribunal noted that the provisions were reversed on the first day of the subsequent financial year, negating any tax deduction failure. Additionally, the ITAT upheld the depreciation claim on an intangible asset with a nil acquisition cost, ruling that the TDS paid on the premium became part of the block of assets and could not be separately disallowed. Consequently, the AO's disallowance of depreciation was quashed, and the appeal was allowed in favor of the assessee.
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