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 HC allowed the appeal and set aside the addition of Rs.25,00,000 made by the AO and upheld by the CIT(A) and the Tribunal, concluding the estimation lacked any material or rational basis. The court found no justification to infer undisclosed sales or suppress books where purchases and sales were duly recorded and the purchase price rose due to foreign exchange movements. The AO's conclusion of a dip in gross profit, based on the fact that approximately 95% of sales were to a related concern, was unsupported by comparative data from like business periods; the Tribunal's contrary finding was characterized as perverse. Relief granted to the assessee; addition deleted.
The HC allowed the appeal and set aside the addition of Rs.25,00,000 made by the AO and upheld by the CIT(A) and the Tribunal, concluding the estimation lacked any material or rational basis. The court found no justification to infer undisclosed sales or suppress books where purchases and sales were duly recorded and the purchase price rose due to foreign exchange movements. The AO's conclusion of a dip in gross profit, based on the fact that approximately 95% of sales were to a related concern, was unsupported by comparative data from like business periods; the Tribunal's contrary finding was characterized as perverse. Relief granted to the assessee; addition deleted.
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