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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT allowed the appellant's appeal, directing the AO to assess the assessee under section 44ADA. The tribunal rejected the Revenue's contention that the assessee, receiving remuneration as a working partner, was ineligible for the presumptive taxation scheme under section 44ADA. It held that neither claiming expenditure nor carrying out independent professional activities outside the partnership is a precondition for invoking section 44ADA. The tribunal applied a strict interpretation, overruling the AO's and DR's arguments, and clarified that remuneration received as a partner in a firm engaged in specified professional activities qualifies for presumptive income computation under section 44ADA. The matter was remanded for assessment in accordance with the applicable law.
The ITAT allowed the appellant's appeal, directing the AO to assess the assessee under section 44ADA. The tribunal rejected the Revenue's contention that the assessee, receiving remuneration as a working partner, was ineligible for the presumptive taxation scheme under section 44ADA. It held that neither claiming expenditure nor carrying out independent professional activities outside the partnership is a precondition for invoking section 44ADA. The tribunal applied a strict interpretation, overruling the AO's and DR's arguments, and clarified that remuneration received as a partner in a firm engaged in specified professional activities qualifies for presumptive income computation under section 44ADA. The matter was remanded for assessment in accordance with the applicable law.
Note: It is a system-generated summary and is for quick reference only.