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 upheld the CIT(A)'s determinations largely in favour of the assessee, dismissing the revenue's grounds of appeal. The Tribunal directed the AO to allow TDS credit pro rata to the extent income was recognised in the relevant year, confirmed deletion of additions relating to bogus discounts, post-sales discounts, reverse charge service tax, bad-debts write-offs, provisions for spare parts, obsolescence and various purchase/service disallowances, and allowed specified business expenditures and depreciation claims. ITAT remitted certain accrual entries for AO verification and directed deletion of challenged additions where evidence established expense genuineness or prior taxation, ordering consequential adjustments.
ITAT upheld the CIT(A)'s determinations largely in favour of the assessee, dismissing the revenue's grounds of appeal. The Tribunal directed the AO to allow TDS credit pro rata to the extent income was recognised in the relevant year, confirmed deletion of additions relating to bogus discounts, post-sales discounts, reverse charge service tax, bad-debts write-offs, provisions for spare parts, obsolescence and various purchase/service disallowances, and allowed specified business expenditures and depreciation claims. ITAT remitted certain accrual entries for AO verification and directed deletion of challenged additions where evidence established expense genuineness or prior taxation, ordering consequential adjustments.
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