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 upheld that additions under section 69C were predicated on non-availability and doubtful identity of five suppliers, lack of evidence of delivery and commercial substance, and unexamined GST input tax credit (ITC) implications. The Tribunal restored the matter to the Assessing Officer for de novo adjudication limited to reconciling ITC claimed under the GST law in respect of the impugned purchases, including obtaining GST return and ITC status of the five suppliers from GST authorities if necessary, and examining how any denial of ITC affects commercial rationality and the assessee's claimed transactions. Appeal of the Revenue allowed for statistical purposes.
ITAT upheld that additions under section 69C were predicated on non-availability and doubtful identity of five suppliers, lack of evidence of delivery and commercial substance, and unexamined GST input tax credit (ITC) implications. The Tribunal restored the matter to the Assessing Officer for de novo adjudication limited to reconciling ITC claimed under the GST law in respect of the impugned purchases, including obtaining GST return and ITC status of the five suppliers from GST authorities if necessary, and examining how any denial of ITC affects commercial rationality and the assessee's claimed transactions. Appeal of the Revenue allowed for statistical purposes.
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