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 upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
ITAT upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
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