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 allowed the appeal in part and set aside additions sustained by the AO and CIT(A). The Tribunal held that receipts shown as corpus donations and certain unsecured advances could not be taxed as anonymous donations under s.115BBC where the assessee produced records establishing name, address and PAN; consequently additions under s.115BBC were deleted and grounds 2 and 3 allowed. Regarding unexplained liabilities under s.68, ITAT accepted the assessee's explanation that amounts represented retention/security deposits under contracts and, given undisputed construction expenses, directed deletion of the additions. Overall, the impugned additions were quashed and the relevant appeal grounds allowed.
ITAT allowed the appeal in part and set aside additions sustained by the AO and CIT(A). The Tribunal held that receipts shown as corpus donations and certain unsecured advances could not be taxed as anonymous donations under s.115BBC where the assessee produced records establishing name, address and PAN; consequently additions under s.115BBC were deleted and grounds 2 and 3 allowed. Regarding unexplained liabilities under s.68, ITAT accepted the assessee's explanation that amounts represented retention/security deposits under contracts and, given undisputed construction expenses, directed deletion of the additions. Overall, the impugned additions were quashed and the relevant appeal grounds allowed.
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