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 directed that deduction under s.10AA be computed unit-wise and claimed from the assessee's total income without setting off losses of one SEZ unit against profits of other SEZ units and without aggregating export or total turnover across units; the AO is directed to recompute accordingly. Interest and other specified miscellaneous incomes attributable to SEZ units are eligible for s.10AA deduction and must be allowed. Foreign tax credit relating to income eligible for s.10AA is to be permitted. A s.37(1) claim for foreign taxes not claimable under ss.90/91 is remanded to the AO for fresh scrutiny. Disallowance under s.14A r.w. r.8D and addition for brand-building expenditure are deleted. Deduction under s.32AC is allowed.
ITAT directed that deduction under s.10AA be computed unit-wise and claimed from the assessee's total income without setting off losses of one SEZ unit against profits of other SEZ units and without aggregating export or total turnover across units; the AO is directed to recompute accordingly. Interest and other specified miscellaneous incomes attributable to SEZ units are eligible for s.10AA deduction and must be allowed. Foreign tax credit relating to income eligible for s.10AA is to be permitted. A s.37(1) claim for foreign taxes not claimable under ss.90/91 is remanded to the AO for fresh scrutiny. Disallowance under s.14A r.w. r.8D and addition for brand-building expenditure are deleted. Deduction under s.32AC is allowed.
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