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 the TPO's order implementing the DRP's directions is an internal procedural act, not requiring electronic visibility or independent appeal. The AO's assessment was quashed for non-compliance with DRP directions, specifically for incorrectly treating the cost of steam as nil and making excessive ALP adjustments contrary to section 144C(13). The Tribunal deleted upward adjustments on electricity sales made by AO/TPO and DRP, accepting the CUP method for valuation. The DRP's direction to nullify the section 80IA deduction on steam transfer was set aside, allowing the assessee's claim based on expert evidence and proper benchmarking. Deduction under section 35(2AB) was denied for lack of prescribed Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues regarding double disallowance of RoU depreciation, amortized loan processing fees, and computational errors were remitted to AO for factual verification and appropriate relief.
The ITAT upheld that the TPO's order implementing the DRP's directions is an internal procedural act, not requiring electronic visibility or independent appeal. The AO's assessment was quashed for non-compliance with DRP directions, specifically for incorrectly treating the cost of steam as nil and making excessive ALP adjustments contrary to section 144C(13). The Tribunal deleted upward adjustments on electricity sales made by AO/TPO and DRP, accepting the CUP method for valuation. The DRP's direction to nullify the section 80IA deduction on steam transfer was set aside, allowing the assessee's claim based on expert evidence and proper benchmarking. Deduction under section 35(2AB) was denied for lack of prescribed Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues regarding double disallowance of RoU depreciation, amortized loan processing fees, and computational errors were remitted to AO for factual verification and appropriate relief.
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