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 assessee's appeal concerning the disallowance of excess depreciation claimed on plant and machinery used for less than 180 days. The assessee had erroneously claimed depreciation at 15% instead of the permissible 7.5% rate. Recognizing this as a bona fide mistake and noting no ineligibility on the part of the assessee, the tribunal held that additional depreciation should be allowed. Consequently, the difference in income reported under business and profession was rectified in favor of the assessee.
The ITAT allowed the assessee's appeal concerning the disallowance of excess depreciation claimed on plant and machinery used for less than 180 days. The assessee had erroneously claimed depreciation at 15% instead of the permissible 7.5% rate. Recognizing this as a bona fide mistake and noting no ineligibility on the part of the assessee, the tribunal held that additional depreciation should be allowed. Consequently, the difference in income reported under business and profession was rectified in favor of the assessee.
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