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 upholds several findings of the first appellate authority and otherwise directs varied reliefs and remittals. Additions for sale of opening RIL shares are sustained in favour of the assessee; unexplained investment in RIL shares, PSU bonds and unexplained bank deposits are deleted and AO directed to withdraw corresponding u/s 69 additions. Additions relating to certain Colgate share purchases and NBS Industries are restored to the file of the AO for verification of contract notes and particulars. Depreciation on leased plant is allowed; bill-discounting charges and money-market losses are accepted as claimed. Accrued interest on 13% NLC bonds is sustained. Interest expenditure claim and quantification, computation of interest u/s 234B (after TDS), and other limited issues are remitted to the AO for determination in accordance with law.
ITAT upholds several findings of the first appellate authority and otherwise directs varied reliefs and remittals. Additions for sale of opening RIL shares are sustained in favour of the assessee; unexplained investment in RIL shares, PSU bonds and unexplained bank deposits are deleted and AO directed to withdraw corresponding u/s 69 additions. Additions relating to certain Colgate share purchases and NBS Industries are restored to the file of the AO for verification of contract notes and particulars. Depreciation on leased plant is allowed; bill-discounting charges and money-market losses are accepted as claimed. Accrued interest on 13% NLC bonds is sustained. Interest expenditure claim and quantification, computation of interest u/s 234B (after TDS), and other limited issues are remitted to the AO for determination in accordance with law.
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