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 affirmed that the disallowance under section 14A of the Act is restricted to the quantum of exempt income actually earned by the assessee; the Tribunal followed an earlier ITAT decision in the assessee's own case and directed that any disallowance be limited to the extent of dividend income exempt under the Act. With respect to motor-car expenditures, the Tribunal allowed deduction for depreciation and related car expenses where motor cars, although registered in directors' names, are shown as fixed assets in the balance sheet and used for business purposes; accordingly, such depreciation and ancillary car expenses were admitted as allowable business deductions.
The ITAT affirmed that the disallowance under section 14A of the Act is restricted to the quantum of exempt income actually earned by the assessee; the Tribunal followed an earlier ITAT decision in the assessee's own case and directed that any disallowance be limited to the extent of dividend income exempt under the Act. With respect to motor-car expenditures, the Tribunal allowed deduction for depreciation and related car expenses where motor cars, although registered in directors' names, are shown as fixed assets in the balance sheet and used for business purposes; accordingly, such depreciation and ancillary car expenses were admitted as allowable business deductions.
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