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 held that the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
The ITAT held that the 10% tolerance band in the proviso to s.43CA applies retrospectively to the year under consideration, such that where the difference between the DVO valuation and sale consideration is within 10% no deeming addition arises. Applying the proviso and the Tribunal's precedent, the panel found the variance fell within the tolerance band for AY 2017-18 and therefore deleted the addition under s.43CA. The Tribunal affirmed the CIT(A)'s deletion of the addition, concluding there was no infirmity in treating the sale consideration as the full value of consideration for the impugned assessment year. Decided in favour of assessee.
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