Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
ITAT allows relief to the assessee in part and against the Revenue in part. Depreciation on electrical fittings is confirmed at 10% (not 15%), treating such installations as "furniture and fittings." Addition for foreign-exchange loss allocated by turnover is deleted and CIT(A)'s reversal is restored where losses are identifiable and claimed on actuals. Disallowance under s.40(a)(ia) is negated: late deposit of TDS where tax is deposited before the return filing due date is not disallowable, and CIT(A)'s curative-construction is affirmed. Apportionment of R&D expenses to EOUs is deleted, where the assessee had booked R&D costs to those units. AO's pre-set-off of carried-forward business loss prior to granting s.10B deduction is disapproved and CIT(A)'s treatment is upheld.
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