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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The ITAT affirmed that incriminating material was found during searches of the assessee and its sub-contractors, permitting disallowance of bogus sub-contract expenses, but restricted the quantum to 12.5% of such purchase expenses. The Tribunal held s.153C inapplicable as the assessee was itself searched under s.153A and material seized from others was admissible in the s.153A assessment; denial of cross-examination of third-party witnesses was not fatal where independent corroborative evidence existed. Invocation of ss.69A, 69C and s.115BBE was deleted and s.80IA(4) deduction was allowed as claimed. Disallowance of ESOP and s.35D deductions were deleted. Assessment was held barred by limitation under s.153B.
The ITAT affirmed that incriminating material was found during searches of the assessee and its sub-contractors, permitting disallowance of bogus sub-contract expenses, but restricted the quantum to 12.5% of such purchase expenses. The Tribunal held s.153C inapplicable as the assessee was itself searched under s.153A and material seized from others was admissible in the s.153A assessment; denial of cross-examination of third-party witnesses was not fatal where independent corroborative evidence existed. Invocation of ss.69A, 69C and s.115BBE was deleted and s.80IA(4) deduction was allowed as claimed. Disallowance of ESOP and s.35D deductions were deleted. Assessment was held barred by limitation under s.153B.
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