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 set aside the lower authorities' orders and remanded the matter to the file of the AO for verification of whether the anonymized assessee holds valid registration under s.12A and has complied with statutory conditions (including audit/reporting requirements); if so, AO is directed to allow exemption under s.12A. The Tribunal found denial of s.10(23C) relief to be unsustainable where the assessee had not claimed s.10(23C) and thus was not required to file Form 10BB, distinguishing the properly filed Form 10B for s.12A. The application under s.154 and prior rejections by the CPC were set aside insofar as they precluded the AO's fresh verification. Appeal allowed for statistical purposes.
ITAT set aside the lower authorities' orders and remanded the matter to the file of the AO for verification of whether the anonymized assessee holds valid registration under s.12A and has complied with statutory conditions (including audit/reporting requirements); if so, AO is directed to allow exemption under s.12A. The Tribunal found denial of s.10(23C) relief to be unsustainable where the assessee had not claimed s.10(23C) and thus was not required to file Form 10BB, distinguishing the properly filed Form 10B for s.12A. The application under s.154 and prior rejections by the CPC were set aside insofar as they precluded the AO's fresh verification. Appeal allowed for statistical purposes.
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