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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The ITAT upheld the FAA's determination that amounts received on sale of MEIS/MLFPS scrips constituted capital receipts, applying the amended definition in section 2(24)(xviii) and relevant judicial precedents; it confirmed the FAA's conclusion that such receipt is not taxable as revenue and cannot be adjusted under section 143(1) for the assessment year in question. Noting that Revenue did not challenge the FAA's non-adjustment finding, the Tribunal found no merit in the Department's appeal and dismissed the appeal. The ITAT therefore affirmed the FAA's order as legally correct and in accordance with law.
The ITAT upheld the FAA's determination that amounts received on sale of MEIS/MLFPS scrips constituted capital receipts, applying the amended definition in section 2(24)(xviii) and relevant judicial precedents; it confirmed the FAA's conclusion that such receipt is not taxable as revenue and cannot be adjusted under section 143(1) for the assessment year in question. Noting that Revenue did not challenge the FAA's non-adjustment finding, the Tribunal found no merit in the Department's appeal and dismissed the appeal. The ITAT therefore affirmed the FAA's order as legally correct and in accordance with law.
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