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 reversed the disallowance of the set off of short-term capital losses against corresponding gains by the revenue authorities, who had characterized the transactions as accommodation entries without sufficient material. The tribunal found that the lower authorities relied primarily on the quantum of the claim rather than concrete evidence to reject the set off. Consequently, the ITAT held that the assessee was entitled to set off the short-term capital loss against the gains arising from the sale of shares in multiple entities. The disallowance order was quashed, and the assessee's appeal was allowed, permitting the set off and negating any tax liability on the resultant net position.
The ITAT reversed the disallowance of the set off of short-term capital losses against corresponding gains by the revenue authorities, who had characterized the transactions as accommodation entries without sufficient material. The tribunal found that the lower authorities relied primarily on the quantum of the claim rather than concrete evidence to reject the set off. Consequently, the ITAT held that the assessee was entitled to set off the short-term capital loss against the gains arising from the sale of shares in multiple entities. The disallowance order was quashed, and the assessee's appeal was allowed, permitting the set off and negating any tax liability on the resultant net position.
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