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 remanded the matter to the AO for further inquiry, concluding prima facie that the Revenue has established a case of accommodation entries and alleged bogus purchases. The AO is directed to verify bank statements, inter-alia the cash trail vis-Ã -vis the assessee's cash books, and to obtain relevant information from the GST authorities to determine whether input tax credit was claimed. After conducting these verifications and necessary enquiries, the AO shall adjudicate the issue in accordance with the Income Tax Act. If the assessee fails to produce requisite records, the AO may decide the matter on merits after obtaining GST and banking particulars. Appeal partly allowed for statistical purposes.
ITAT remanded the matter to the AO for further inquiry, concluding prima facie that the Revenue has established a case of accommodation entries and alleged bogus purchases. The AO is directed to verify bank statements, inter-alia the cash trail vis-Ã -vis the assessee's cash books, and to obtain relevant information from the GST authorities to determine whether input tax credit was claimed. After conducting these verifications and necessary enquiries, the AO shall adjudicate the issue in accordance with the Income Tax Act. If the assessee fails to produce requisite records, the AO may decide the matter on merits after obtaining GST and banking particulars. Appeal partly allowed for statistical purposes.
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