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 held that the assessee possessed valid approval under the Act for claiming exemption under section 10(25)(iv) in respect of income received by trustees on behalf of an approved gratuity fund; the Tribunal noted prior allowance of the exemption for A.Y. 2021-22 and 2022-23. For A.Y. 2024-25 the ITAT remitted the issue to the file of the AO for verification of documentary and factual particulars supporting the exemption claim and directed that, if the particulars are found correct, the AO shall allow the exemption in accordance with law. The grounds of appeal advanced by the assessee were allowed for statistical purposes.
The ITAT held that the assessee possessed valid approval under the Act for claiming exemption under section 10(25)(iv) in respect of income received by trustees on behalf of an approved gratuity fund; the Tribunal noted prior allowance of the exemption for A.Y. 2021-22 and 2022-23. For A.Y. 2024-25 the ITAT remitted the issue to the file of the AO for verification of documentary and factual particulars supporting the exemption claim and directed that, if the particulars are found correct, the AO shall allow the exemption in accordance with law. The grounds of appeal advanced by the assessee were allowed for statistical purposes.
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