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 set aside the question of depreciation on goodwill arising from amalgamation and remitted the matter to the file of the CIT(A) for de novo consideration, holding that the CIT(A) made no specific finding because the assessee failed to furnish essential documents (amalgamation order, pre- and post-amalgamation financials, goodwill computation) and did not dispute those facts. The CIT(A) is directed to call for the requisite documents, afford the assessee a fresh opportunity of hearing, and decide the issue on merits after considering any material the assessee may tender. The appeals of the assessee are allowed for statistical purposes.
The ITAT set aside the question of depreciation on goodwill arising from amalgamation and remitted the matter to the file of the CIT(A) for de novo consideration, holding that the CIT(A) made no specific finding because the assessee failed to furnish essential documents (amalgamation order, pre- and post-amalgamation financials, goodwill computation) and did not dispute those facts. The CIT(A) is directed to call for the requisite documents, afford the assessee a fresh opportunity of hearing, and decide the issue on merits after considering any material the assessee may tender. The appeals of the assessee are allowed for statistical purposes.
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