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 appellate authority's deletion of an addition under s.69A read with s.115BBE, concluding the assessee satisfactorily explained cash deposits (approx. Rs.39.84 crore) as receipts from its educational and medical activities and redeposits from bank withdrawals. The Tribunal found the AO made no cogent enquiry, did not reject the books of account, and the receipts were reflected in the assessee's gross receipts and audited accounts; consequently the impugned addition amounted to double taxation on disclosed receipts. ITAT refused remand, held the evidentiary materials placed before the AO had been duly considered by CIT(A), and affirmed deletion of the addition. Decision pronounced against the revenue.
ITAT upheld the appellate authority's deletion of an addition under s.69A read with s.115BBE, concluding the assessee satisfactorily explained cash deposits (approx. Rs.39.84 crore) as receipts from its educational and medical activities and redeposits from bank withdrawals. The Tribunal found the AO made no cogent enquiry, did not reject the books of account, and the receipts were reflected in the assessee's gross receipts and audited accounts; consequently the impugned addition amounted to double taxation on disclosed receipts. ITAT refused remand, held the evidentiary materials placed before the AO had been duly considered by CIT(A), and affirmed deletion of the addition. Decision pronounced against the revenue.
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