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 sustains taxation of unaccounted brokerage and commissions in part: brokerage income of Rs. 11,500 and commission on interest are held exigible; of the aggregate additions made by AO, net addition of Rs. 42,850 is sustained and the remaining additions are deleted. The assessee's claim of expenses (Rs. 7,33,440) lacked documentary support and is disallowed, but ITAT directs allowance of reasonable expenditure by deeming 75% of such receipts as deductible business expenditure, thereby taxing 25% as net income. Grounds raised by the assessee are partly allowed and partly dismissed accordingly; assessment is restored to the extent specified for computation.
ITAT sustains taxation of unaccounted brokerage and commissions in part: brokerage income of Rs. 11,500 and commission on interest are held exigible; of the aggregate additions made by AO, net addition of Rs. 42,850 is sustained and the remaining additions are deleted. The assessee's claim of expenses (Rs. 7,33,440) lacked documentary support and is disallowed, but ITAT directs allowance of reasonable expenditure by deeming 75% of such receipts as deductible business expenditure, thereby taxing 25% as net income. Grounds raised by the assessee are partly allowed and partly dismissed accordingly; assessment is restored to the extent specified for computation.
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