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 the Principal CIT's revision under section 263, ruling that the AO failed to properly scrutinize the depreciation claim on goodwill in AY 2018-19, despite its disallowance in the immediately preceding year. The Tribunal rejected the assessee's contention invoking the principle of consistency, noting that the claim was disallowed previously on identical facts and no new evidence or change in circumstances justified its allowance. The subsequent allowance of depreciation in later years was deemed irrelevant and could not validate an earlier erroneous acceptance. The misclassification of goodwill as a tangible asset further indicated inadequate examination by the AO. Consequently, the revision was confirmed, affirming that the AO should have disallowed the depreciation claim in AY 2018-19, consistent with the prior year's findings. The appeal was dismissed.
The ITAT upheld the Principal CIT's revision under section 263, ruling that the AO failed to properly scrutinize the depreciation claim on goodwill in AY 2018-19, despite its disallowance in the immediately preceding year. The Tribunal rejected the assessee's contention invoking the principle of consistency, noting that the claim was disallowed previously on identical facts and no new evidence or change in circumstances justified its allowance. The subsequent allowance of depreciation in later years was deemed irrelevant and could not validate an earlier erroneous acceptance. The misclassification of goodwill as a tangible asset further indicated inadequate examination by the AO. Consequently, the revision was confirmed, affirming that the AO should have disallowed the depreciation claim in AY 2018-19, consistent with the prior year's findings. The appeal was dismissed.
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