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 held that the AO's disallowance under section 14A was unsustainable as no dissatisfaction with the assessee's suo motu disallowance was recorded before invoking Rule 8D, allowing the assessee's appeal. Regarding additions under section 43CA, the tribunal found the difference between the sale price and stamp duty value within the 10% tolerance limit, negating any addition. On foreign currency translation differences, the matter was remitted to the AO for verification due to inadequate examination during assessment and appeal stages. Lastly, the tribunal upheld the CIT(A)'s confirmation of the AO's disallowance of carry-forward long-term capital loss where STT was paid, citing the risk of unverified set-offs against unrelated gains in future years.
The ITAT held that the AO's disallowance under section 14A was unsustainable as no dissatisfaction with the assessee's suo motu disallowance was recorded before invoking Rule 8D, allowing the assessee's appeal. Regarding additions under section 43CA, the tribunal found the difference between the sale price and stamp duty value within the 10% tolerance limit, negating any addition. On foreign currency translation differences, the matter was remitted to the AO for verification due to inadequate examination during assessment and appeal stages. Lastly, the tribunal upheld the CIT(A)'s confirmation of the AO's disallowance of carry-forward long-term capital loss where STT was paid, citing the risk of unverified set-offs against unrelated gains in future years.
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