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 allowed deduction under sec.43B for amounts paid in the relevant FY and directed deletion of service tax payment of Rs.1,40,23,520 and disallowance relating to TDS, finding these were paid in the FY relevant to AY 2018-19 and reflected in ITR-6 and audit reports; it sustained disallowance of Rs.1,03,93,805 for unpaid liabilities where supporting challans/evidence were not produced. ITAT set aside the CIT(A) order and remitted the matter to the AO to give effect to these findings, delete the specified additions, and to modify penalty proceedings under sec.270A accordingly after recalculation in light of the allowed reliefs.
ITAT allowed deduction under sec.43B for amounts paid in the relevant FY and directed deletion of service tax payment of Rs.1,40,23,520 and disallowance relating to TDS, finding these were paid in the FY relevant to AY 2018-19 and reflected in ITR-6 and audit reports; it sustained disallowance of Rs.1,03,93,805 for unpaid liabilities where supporting challans/evidence were not produced. ITAT set aside the CIT(A) order and remitted the matter to the AO to give effect to these findings, delete the specified additions, and to modify penalty proceedings under sec.270A accordingly after recalculation in light of the allowed reliefs.
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