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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
ITAT upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
