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 approach that only the profit element embedded in alleged bogus purchases of yarn and cloth is exigible to tax, not the entire supplier payments. The Tribunal found the estimation of the taxable profit at 12.5% of purchases to be fair and reasonable and refused any further addition. With respect to alleged on-money paid on acquisition of immovable property, the Tribunal rejected the Revenue's reliance on a retracted survey admission under s.133A, holding such survey statements lack conclusive evidentiary value absent corroborative material; no independent evidence was produced, so the addition based solely on the survey admission was dismissed.
ITAT upheld the CIT(A)'s approach that only the profit element embedded in alleged bogus purchases of yarn and cloth is exigible to tax, not the entire supplier payments. The Tribunal found the estimation of the taxable profit at 12.5% of purchases to be fair and reasonable and refused any further addition. With respect to alleged on-money paid on acquisition of immovable property, the Tribunal rejected the Revenue's reliance on a retracted survey admission under s.133A, holding such survey statements lack conclusive evidentiary value absent corroborative material; no independent evidence was produced, so the addition based solely on the survey admission was dismissed.
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