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 that disallowance under s.14A read with Rule 8D was not attracted where exempt-income-bearing securities were held as stock-in-trade, and the related Rule 8D(2)(iii) disallowance was deleted in favour of the assessee. The issue of provision for wage revision was remitted to the AO for de novo adjudication after examination of the Memorandum of Settlement. Section 115JB was held inapplicable to the assessee-bank as a corresponding new bank. Shifting loss on transfer from AFS to HTM was held allowable and quantification remitted to the AO. Additions for bad debts and interest accrued but not due were deleted, broken-period interest treated as revenue, penalty u/s 271(1)(c) deleted, and the s.154 rectification quashed.
ITAT affirmed that disallowance under s.14A read with Rule 8D was not attracted where exempt-income-bearing securities were held as stock-in-trade, and the related Rule 8D(2)(iii) disallowance was deleted in favour of the assessee. The issue of provision for wage revision was remitted to the AO for de novo adjudication after examination of the Memorandum of Settlement. Section 115JB was held inapplicable to the assessee-bank as a corresponding new bank. Shifting loss on transfer from AFS to HTM was held allowable and quantification remitted to the AO. Additions for bad debts and interest accrued but not due were deleted, broken-period interest treated as revenue, penalty u/s 271(1)(c) deleted, and the s.154 rectification quashed.
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