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 set aside the first appellate authority's orders and remanded the matter to the AO for fresh determination of the Annual Lettable Value (ALV) of the house property in accordance with the guidelines established by the jurisdictional High Court, emphasizing that the AO must consider the Municipal Ratable Value (MRV) unless compelling reasons exist to reject it. The AO's prior reliance on an expired lease deed without inquiry into MRV was held inadequate. Regarding disallowance under section 14A read with Rule 8D, the AO was directed to verify the assessee's computation and limit the disallowance strictly to investments yielding exempt income during the relevant year. Both grounds were allowed for reconsideration in line with these directions.
The ITAT set aside the first appellate authority's orders and remanded the matter to the AO for fresh determination of the Annual Lettable Value (ALV) of the house property in accordance with the guidelines established by the jurisdictional High Court, emphasizing that the AO must consider the Municipal Ratable Value (MRV) unless compelling reasons exist to reject it. The AO's prior reliance on an expired lease deed without inquiry into MRV was held inadequate. Regarding disallowance under section 14A read with Rule 8D, the AO was directed to verify the assessee's computation and limit the disallowance strictly to investments yielding exempt income during the relevant year. Both grounds were allowed for reconsideration in line with these directions.
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