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 set aside the CIT(A)'s order as cryptic and unsustainable, finding the AO's denial of the assessee's deduction under s.80IA was not supported by consideration of the assessee's submissions and the belated Form 10CCB audit report. The Tribunal remanded the matter to the CIT(A) to adjudicate afresh, directing that the previously filed submissions, the departmental acceptance of an identical claim for the initial assessment year, and the contemporaneous allowance of s.80JJA be given due weight. The AO/CIT(A) was instructed to decide the claim on merits in accordance with law after allowing the assessee an opportunity of personal hearing.
The ITAT set aside the CIT(A)'s order as cryptic and unsustainable, finding the AO's denial of the assessee's deduction under s.80IA was not supported by consideration of the assessee's submissions and the belated Form 10CCB audit report. The Tribunal remanded the matter to the CIT(A) to adjudicate afresh, directing that the previously filed submissions, the departmental acceptance of an identical claim for the initial assessment year, and the contemporaneous allowance of s.80JJA be given due weight. The AO/CIT(A) was instructed to decide the claim on merits in accordance with law after allowing the assessee an opportunity of personal hearing.
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