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 allowed the assessee's appeal and set aside the addition of Rs.50 lakhs by directing deletion of the disallowance under section 11(2). The Tribunal found both Form No.10 and Form No.10BB were filed within the statutory due date, and the revised audit report in Form No.10BB rectifying the mismatch was submitted to CPC before processing under section 143(1). Applying consistent tribunal precedent, the ITAT held such rectification constitutes compliance with statutory requirements and precludes denial of exemption under section 11. The CPC's disallowance, sustained by the Ld. CIT(A), was held not in accordance with law and the exemption was restored.
The ITAT allowed the assessee's appeal and set aside the addition of Rs.50 lakhs by directing deletion of the disallowance under section 11(2). The Tribunal found both Form No.10 and Form No.10BB were filed within the statutory due date, and the revised audit report in Form No.10BB rectifying the mismatch was submitted to CPC before processing under section 143(1). Applying consistent tribunal precedent, the ITAT held such rectification constitutes compliance with statutory requirements and precludes denial of exemption under section 11. The CPC's disallowance, sustained by the Ld. CIT(A), was held not in accordance with law and the exemption was restored.
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