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 upheld the CIT(A)'s deletion of disallowances under sections 80IC and 10AA relating to allocation of indirect Head Office expenses, relying on precedent from the assessee's own case. Regarding foreign travel and club expenses, the Tribunal reduced the disallowance to 10% and 20% respectively, modifying the CIT(A)'s higher percentages, thereby partially allowing the assessee's grounds. The disallowance under section 10AA on scrap sales was deleted, as the sales were held connected to export activities, consistent with prior coordinate bench rulings. The section 14A disallowance was upheld per coordinate bench decisions favoring the assessee, resulting in dismissal of the Revenue's ground. Finally, the disallowance of depreciation on software licenses was rejected, affirming the CIT(A)'s reliance on established precedent. Consequently, the appeal was partly allowed in favor of the assessee with consequential relief granted.
The ITAT upheld the CIT(A)'s deletion of disallowances under sections 80IC and 10AA relating to allocation of indirect Head Office expenses, relying on precedent from the assessee's own case. Regarding foreign travel and club expenses, the Tribunal reduced the disallowance to 10% and 20% respectively, modifying the CIT(A)'s higher percentages, thereby partially allowing the assessee's grounds. The disallowance under section 10AA on scrap sales was deleted, as the sales were held connected to export activities, consistent with prior coordinate bench rulings. The section 14A disallowance was upheld per coordinate bench decisions favoring the assessee, resulting in dismissal of the Revenue's ground. Finally, the disallowance of depreciation on software licenses was rejected, affirming the CIT(A)'s reliance on established precedent. Consequently, the appeal was partly allowed in favor of the assessee with consequential relief granted.
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