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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In revision under s. 263, PCIT contended the assessment was erroneous for allowing depreciation on opening WDV without first setting off brought-forward additional depreciation from the preceding year. ITAT reversed, holding there is no statutory requirement to reduce opening WDV by carried-forward additional depreciation before computing current-year depreciation; depreciation is to be computed by applying the prescribed rate to the asset's opening WDV. Consequently, the PCIT's conclusion of error in the AO's assessment was erroneous. The assessment stands as passed, the s. 263 revision direction quashed, and the assessee's appeal is allowed.
In revision under s. 263, PCIT contended the assessment was erroneous for allowing depreciation on opening WDV without first setting off brought-forward additional depreciation from the preceding year. ITAT reversed, holding there is no statutory requirement to reduce opening WDV by carried-forward additional depreciation before computing current-year depreciation; depreciation is to be computed by applying the prescribed rate to the asset's opening WDV. Consequently, the PCIT's conclusion of error in the AO's assessment was erroneous. The assessment stands as passed, the s. 263 revision direction quashed, and the assessee's appeal is allowed.
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