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 affirmed the appellate findings and dismissed all grounds raised by the revenue. The Tribunal held that the addition for cash deposits during demonetisation could not be sustained because the revenue failed to controvert the finding that the assessee possessed sufficient cash on hand, and speculative inferences as to the source were impermissible. On characterization of sale proceeds, ITAT upheld CIT(A)'s factual conclusion that most land parcels constituted stock-in-trade while certain plots were consistently held as capital assets, rejecting the AO's contrary stance. With respect to interest deduction under section 24(b) on rental receipts, ITAT accepted CIT(A)'s allowance and reasoning that the return misdescribed the receipts, thereby dismissing the revenue's appeal.
ITAT affirmed the appellate findings and dismissed all grounds raised by the revenue. The Tribunal held that the addition for cash deposits during demonetisation could not be sustained because the revenue failed to controvert the finding that the assessee possessed sufficient cash on hand, and speculative inferences as to the source were impermissible. On characterization of sale proceeds, ITAT upheld CIT(A)'s factual conclusion that most land parcels constituted stock-in-trade while certain plots were consistently held as capital assets, rejecting the AO's contrary stance. With respect to interest deduction under section 24(b) on rental receipts, ITAT accepted CIT(A)'s allowance and reasoning that the return misdescribed the receipts, thereby dismissing the revenue's appeal.
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