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 GST amount shall not be included in computing presumptive income under Section 44B of the Act, following its prior decision for AY 2020-21, thereby deleting the addition made by the AO for AY 2022-23. The Tribunal reaffirmed that the Assessee, entitled to treaty benefits under Article 8, cannot have GST considered in deemed business income computations. Additionally, the Tribunal ruled that provisions of Section 115JB relating to MAT and the computation of 'Book Profits' do not apply to the Assessee, based on Explanation 4A to Section 115JB(1), consistent with its earlier decision under identical facts. Accordingly, all contested additions and MAT applicability were set aside in favor of the Assessee.
The ITAT upheld that GST amount shall not be included in computing presumptive income under Section 44B of the Act, following its prior decision for AY 2020-21, thereby deleting the addition made by the AO for AY 2022-23. The Tribunal reaffirmed that the Assessee, entitled to treaty benefits under Article 8, cannot have GST considered in deemed business income computations. Additionally, the Tribunal ruled that provisions of Section 115JB relating to MAT and the computation of 'Book Profits' do not apply to the Assessee, based on Explanation 4A to Section 115JB(1), consistent with its earlier decision under identical facts. Accordingly, all contested additions and MAT applicability were set aside in favor of the Assessee.
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