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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The ITAT upheld in part the AO's disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.
The ITAT upheld in part the AO's disallowance: where the assessee borrowed at 12% and advanced interest-bearing loans at 5% to five related entities, a 7% interest disallowance is warranted and the AO is directed to compute and quantify that disallowance. For other advances, the ITAT required the assessee to produce a cash-flow statement and full particulars of loans squared-off to enable the AO to segregate interest-bearing funds from interest-free funds; disallowance is to be computed only to the extent interest-bearing funds were advanced interest-free. The AO must also reassess interest under section 234A only from the extended filing due date.
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