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 allowed the revision under section 263 concerning the allowability of a donation claimed under section 80GGC. The tribunal held that the assessing officer failed to conduct any inquiry regarding the donation made to a political party, specifically the Rashtriya Samajwadi Party (Secular), as no notice under section 142(1) was issued. The reliance on precedent adverse to the deduction claim was noted, but the lack of examination by the AO rendered the disallowance improper. Consequently, the revision was allowed, and the assessing officer was directed to examine the claim afresh. The assessee's grounds challenging the revision were dismissed as devoid of merit.
The ITAT allowed the revision under section 263 concerning the allowability of a donation claimed under section 80GGC. The tribunal held that the assessing officer failed to conduct any inquiry regarding the donation made to a political party, specifically the Rashtriya Samajwadi Party (Secular), as no notice under section 142(1) was issued. The reliance on precedent adverse to the deduction claim was noted, but the lack of examination by the AO rendered the disallowance improper. Consequently, the revision was allowed, and the assessing officer was directed to examine the claim afresh. The assessee's grounds challenging the revision were dismissed as devoid of merit.
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