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 allowed the appeal of the Appellant and directed the Assessing Officer to accept the claim for deduction under section 10AA where a revised audit report in Form 56F was filed during assessment proceedings. The Tribunal rejected the Revenue's contention that Form 56F, filed after issuance of the show-cause notice and not with the original return, disqualified the Appellant from claiming section 10AA. Relying on judicial precedents and noting the subsequent legislative amendment effective 01.04.2024 (A.Y. 2024-25) requiring return filing under section 139(1) for future claims, the Tribunal concluded no such temporal precondition existed for the year under consideration and held the Appellant entitled to deduction.
ITAT allowed the appeal of the Appellant and directed the Assessing Officer to accept the claim for deduction under section 10AA where a revised audit report in Form 56F was filed during assessment proceedings. The Tribunal rejected the Revenue's contention that Form 56F, filed after issuance of the show-cause notice and not with the original return, disqualified the Appellant from claiming section 10AA. Relying on judicial precedents and noting the subsequent legislative amendment effective 01.04.2024 (A.Y. 2024-25) requiring return filing under section 139(1) for future claims, the Tribunal concluded no such temporal precondition existed for the year under consideration and held the Appellant entitled to deduction.
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