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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HC dismissed the assessee's challenge and upheld the concurrent findings of the AO, CIT(A) and ITAT that the premises' annual value under s.23 was Rs.22,00,000. The court held the assessee could not rely on developer/society letters not pressed before the tribunal and had failed to prove any municipal rateable value; the doctrine of standard rent was inapplicable as no statutory tenancy under rent control existed. The AO permissibly conducted an independent enquiry, considering comparable instances, overdraft return and the usufructual effect of a substantial security deposit; notional interest alone could not determine annual value. Decision against the assessee.
HC dismissed the assessee's challenge and upheld the concurrent findings of the AO, CIT(A) and ITAT that the premises' annual value under s.23 was Rs.22,00,000. The court held the assessee could not rely on developer/society letters not pressed before the tribunal and had failed to prove any municipal rateable value; the doctrine of standard rent was inapplicable as no statutory tenancy under rent control existed. The AO permissibly conducted an independent enquiry, considering comparable instances, overdraft return and the usufructual effect of a substantial security deposit; notional interest alone could not determine annual value. Decision against the assessee.
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