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 quashed the revisionary exercise by the Pr. CIT under s. 263, holding the Pr. CIT lacked jurisdiction to revise the assessment in respect of the assessee's claim for deduction under s. 80G relating to contributions from CSR funds. The Tribunal found the Assessing Officer had, in fact, examined the s. 80G claim by issuing a questionnaire and receiving detailed replies, and noted consistent tribunal precedents favoring the assessee's entitlement. Consequently the reassessment/ revision was set aside and the appeal filed by the assessee was allowed, confirming the allowability of the s. 80G deduction in the assessment under challenge.
The ITAT quashed the revisionary exercise by the Pr. CIT under s. 263, holding the Pr. CIT lacked jurisdiction to revise the assessment in respect of the assessee's claim for deduction under s. 80G relating to contributions from CSR funds. The Tribunal found the Assessing Officer had, in fact, examined the s. 80G claim by issuing a questionnaire and receiving detailed replies, and noted consistent tribunal precedents favoring the assessee's entitlement. Consequently the reassessment/ revision was set aside and the appeal filed by the assessee was allowed, confirming the allowability of the s. 80G deduction in the assessment under challenge.
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