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 dismissed the appeal and upheld the PCIT's revision order under s. 263, holding the AO's assessment to be erroneous and prejudicial to the revenue for failing to disallow unpaid VAT under s. 43B(a) as noted in the auditor's Form 3CD and for neglecting to treat belated employee PF contribution as income under s. 2(24)(x). The PCIT's remand to the AO for verification was validated given the recorded failure of the AO to investigate these issues, warranting exercise of revisional jurisdiction. Consequently, the PCIT's direction stands and the assessee's appeal is rejected.
ITAT dismissed the appeal and upheld the PCIT's revision order under s. 263, holding the AO's assessment to be erroneous and prejudicial to the revenue for failing to disallow unpaid VAT under s. 43B(a) as noted in the auditor's Form 3CD and for neglecting to treat belated employee PF contribution as income under s. 2(24)(x). The PCIT's remand to the AO for verification was validated given the recorded failure of the AO to investigate these issues, warranting exercise of revisional jurisdiction. Consequently, the PCIT's direction stands and the assessee's appeal is rejected.
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