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 that the exemption under Section 10(10D) does not apply where a life insurance policy is surrendered and the single premium paid exceeds 20% of the capital sum assured, thereby disallowing the exemption on maturity proceeds received upon surrender. However, the Tribunal found that the Assessing Officer's addition was based on an incorrect charging section and erroneous appreciation of facts. Following precedent, the ITAT held that additions made without proper legal basis are unsustainable and invalid. Consequently, the impugned additions were deemed arbitrary and perverse, leading to their deletion. The appellant's appeal was allowed in full.
The ITAT upheld that the exemption under Section 10(10D) does not apply where a life insurance policy is surrendered and the single premium paid exceeds 20% of the capital sum assured, thereby disallowing the exemption on maturity proceeds received upon surrender. However, the Tribunal found that the Assessing Officer's addition was based on an incorrect charging section and erroneous appreciation of facts. Following precedent, the ITAT held that additions made without proper legal basis are unsustainable and invalid. Consequently, the impugned additions were deemed arbitrary and perverse, leading to their deletion. The appellant's appeal was allowed in full.
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