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 assessee's claim for deduction under s.80IA(4)(i) where no claim was made in the original or any revised return filed under s.139(1)/139(4), and requisite documentation (Form No.10CCB) was not placed on record. The deduction was first asserted only before the CIT(A) as an additional ground without filing a return; consequently s.80A(5) applied mandatorily to bar belated claims. The Tribunal held the statutory precondition for raising the deduction during assessment proceedings was unmet, rendering the claim inadmissible. Appeal was decided against the assessee and the deduction was denied.
ITAT dismissed the assessee's claim for deduction under s.80IA(4)(i) where no claim was made in the original or any revised return filed under s.139(1)/139(4), and requisite documentation (Form No.10CCB) was not placed on record. The deduction was first asserted only before the CIT(A) as an additional ground without filing a return; consequently s.80A(5) applied mandatorily to bar belated claims. The Tribunal held the statutory precondition for raising the deduction during assessment proceedings was unmet, rendering the claim inadmissible. Appeal was decided against the assessee and the deduction was denied.
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