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 upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
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