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ITAT upheld that the addition under Sec. 50C could not be sustained without proper inquiry and rescinded the AO's summary finding of unexplained investment under Sec. 69. The tribunal accepted the assessee's evidentiary showing - including a registered sale deed and a subsequent confirmation and ledger extracts from the purchaser - that the sale consideration represented adjustment of outstanding liabilities rather than cash payment, and held that the claim should not have been summarily rejected. The matter is remitted to the A.O. for reenquiry and verification, directing the A.O. to examine relevant persons of the purchaser and undertake any further verifications necessary to determine the true nature of the transaction.
ITAT upheld that the addition under Sec. 50C could not be sustained without proper inquiry and rescinded the AO's summary finding of unexplained investment under Sec. 69. The tribunal accepted the assessee's evidentiary showing - including a registered sale deed and a subsequent confirmation and ledger extracts from the purchaser - that the sale consideration represented adjustment of outstanding liabilities rather than cash payment, and held that the claim should not have been summarily rejected. The matter is remitted to the A.O. for reenquiry and verification, directing the A.O. to examine relevant persons of the purchaser and undertake any further verifications necessary to determine the true nature of the transaction.
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