Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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The ITAT set aside the impugned transfer-pricing adjustments and directed deletion of: (a) the TP adjustment premised on application of the Berry ratio and improperly selected comparables, holding the assessee's transactions with AEs to be at arm's length and that OP/OC (or GP margin/COP) would be the appropriate PLI if TNMM were applied; (b) notional interest on outstanding receivables, finding uniform commercial credit terms and accepted industry practice negated recharacterisation as interest-free loans; (c) addition under s.36(1)(va) for delayed PF payment, on facts showing timely compliance; (d) tax under s.115QA in relation to a share buy-back, on reliance upon prevailing public disclosures; and (e) unexplained expenditure treated on a "dumb document" basis. All challenged grounds allowed.
The ITAT set aside the impugned transfer-pricing adjustments and directed deletion of: (a) the TP adjustment premised on application of the Berry ratio and improperly selected comparables, holding the assessee's transactions with AEs to be at arm's length and that OP/OC (or GP margin/COP) would be the appropriate PLI if TNMM were applied; (b) notional interest on outstanding receivables, finding uniform commercial credit terms and accepted industry practice negated recharacterisation as interest-free loans; (c) addition under s.36(1)(va) for delayed PF payment, on facts showing timely compliance; (d) tax under s.115QA in relation to a share buy-back, on reliance upon prevailing public disclosures; and (e) unexplained expenditure treated on a "dumb document" basis. All challenged grounds allowed.
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