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 AO's invocation of section 153C against the assessee, finding the seized gift deed to be an incriminating document belonging to the assessee and rejecting the contention that no incriminating material was found. However, ITAT deleted additions under section 69 read with section 115BBE insofar as the AO and CIT(A) taxed the entire alleged gift of Rs. 22,40,000 and treated specified bank transfers as routed cash without any inquiry or cogent evidence. ITAT accepted the assessee's contention as to a draft deed and disallowed those additions, but identified an unexplained residual sum of Rs. 1,45,430 requiring factual verification. The matter is remitted to the AO for fresh inquiry and determination.
ITAT upheld the AO's invocation of section 153C against the assessee, finding the seized gift deed to be an incriminating document belonging to the assessee and rejecting the contention that no incriminating material was found. However, ITAT deleted additions under section 69 read with section 115BBE insofar as the AO and CIT(A) taxed the entire alleged gift of Rs. 22,40,000 and treated specified bank transfers as routed cash without any inquiry or cogent evidence. ITAT accepted the assessee's contention as to a draft deed and disallowed those additions, but identified an unexplained residual sum of Rs. 1,45,430 requiring factual verification. The matter is remitted to the AO for fresh inquiry and determination.
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