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 allowed Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
The ITAT allowed Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
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