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 assessee's appeal and dismissed the Revenue's grounds. The Tribunal held that accumulated funds under s.11 were expended in prior assessment years and no accumulated balance remained for application in the year under assessment; the inadvertent inclusion in Schedule I of the ITR for AY 2018-19 resulted from a "punching error." The AO's disallowance, premised on Goetze-based treatment, was rejected because the assessee neither claimed a deduction in the return nor during assessment proceedings based on prior accumulated funds. Consequently, the addition for alleged non-utilisation of accumulated funds was set aside and the Revenue's challenge was dismissed.
ITAT allowed the assessee's appeal and dismissed the Revenue's grounds. The Tribunal held that accumulated funds under s.11 were expended in prior assessment years and no accumulated balance remained for application in the year under assessment; the inadvertent inclusion in Schedule I of the ITR for AY 2018-19 resulted from a "punching error." The AO's disallowance, premised on Goetze-based treatment, was rejected because the assessee neither claimed a deduction in the return nor during assessment proceedings based on prior accumulated funds. Consequently, the addition for alleged non-utilisation of accumulated funds was set aside and the Revenue's challenge was dismissed.
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