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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ITAT upheld initiation of reassessment under s.147/s.148, finding nondisclosure of a transfer of immovable property and resultant capital gains in the return. Noting the assessee's ex parte conduct before the AO and CIT(A), the Tribunal confirmed reopening but, in the interest of natural justice, directed the AO to verify payment of Rs.5,00,000 by cheque in May 2010 to original owners; if established as consideration, the amount is to be allowed as deduction under s.48 against deemed sale consideration determined under s.50C. Observing repeated opportunities afforded to the assessee, the ITAT restored the matter to the AO for fresh adjudication on merits and allowed the appeal for statistical purposes.
ITAT upheld initiation of reassessment under s.147/s.148, finding nondisclosure of a transfer of immovable property and resultant capital gains in the return. Noting the assessee's ex parte conduct before the AO and CIT(A), the Tribunal confirmed reopening but, in the interest of natural justice, directed the AO to verify payment of Rs.5,00,000 by cheque in May 2010 to original owners; if established as consideration, the amount is to be allowed as deduction under s.48 against deemed sale consideration determined under s.50C. Observing repeated opportunities afforded to the assessee, the ITAT restored the matter to the AO for fresh adjudication on merits and allowed the appeal for statistical purposes.
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