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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT allowed the assessee's challenges to additions made under s.153A and disallowances premised solely on a statement allegedly recorded u/s 132(4) where no incriminating material was seized and the statement was retracted, holding such statement lacked evidentiary value and cannot sustain additions absent corroboration; accordingly ground nos. addressing that issue were allowed. The Tribunal held the AO's sample one-month extrapolation and permutation-and-combination estimates were arbitrary and impermissible. The Tribunal nonetheless upheld a limited disallowance for amounts characterised as penal ("Shashti") while treating other payments as compensatory, and disallowed the CIT(A)'s direction compelling fresh month-wise submissions as beyond authority; relevant grounds were partly allowed/allowed.
The ITAT allowed the assessee's challenges to additions made under s.153A and disallowances premised solely on a statement allegedly recorded u/s 132(4) where no incriminating material was seized and the statement was retracted, holding such statement lacked evidentiary value and cannot sustain additions absent corroboration; accordingly ground nos. addressing that issue were allowed. The Tribunal held the AO's sample one-month extrapolation and permutation-and-combination estimates were arbitrary and impermissible. The Tribunal nonetheless upheld a limited disallowance for amounts characterised as penal ("Shashti") while treating other payments as compensatory, and disallowed the CIT(A)'s direction compelling fresh month-wise submissions as beyond authority; relevant grounds were partly allowed/allowed.
Note: It is a system-generated summary and is for quick reference only.