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 dismissed the revenue's appeal and upheld the CIT(A)'s findings in favour of the assessee. The Tribunal accepted the assessee's consistent stock-valuation policy (NRV by ageing: current year 100%, one year 90%, two years 80%, older 50%) and noted the AO had earlier accepted similar treatment for another AY; valuation challenge lacked merit. A totalling omission of Rs.10,66,150 established in the survey records was allowed to the assessee. Consequently the Tribunal directed the AO to delete the addition relating to excess stock (net discrepancy
ITAT dismissed the revenue's appeal and upheld the CIT(A)'s findings in favour of the assessee. The Tribunal accepted the assessee's consistent stock-valuation policy (NRV by ageing: current year 100%, one year 90%, two years 80%, older 50%) and noted the AO had earlier accepted similar treatment for another AY; valuation challenge lacked merit. A totalling omission of Rs.10,66,150 established in the survey records was allowed to the assessee. Consequently the Tribunal directed the AO to delete the addition relating to excess stock (net discrepancy
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