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 set aside the impugned disallowances and allowed the claimed deductions. The tribunal deleted the disallowance under s.14A r.w.r.8D, applying the principle that major expenditures must correlate with exempt income. Disallowances of brokerage payments were held to be ordinary course business expenses for entities engaged in commercial property leasing and were deleted where TDS evidence was furnished. Denial of deduction under s.80IAB for car-parking rental income was reversed, the tribunal finding no distinguishing facts to deny the incentive. Settlement fees paid on premature termination of service contracts were characterized as revenue expenditure incurred for commercial expediency (not capital acquisition) and allowed. The ITAT therefore ruled in favour of the assessee on the contested adjustments.
The ITAT set aside the impugned disallowances and allowed the claimed deductions. The tribunal deleted the disallowance under s.14A r.w.r.8D, applying the principle that major expenditures must correlate with exempt income. Disallowances of brokerage payments were held to be ordinary course business expenses for entities engaged in commercial property leasing and were deleted where TDS evidence was furnished. Denial of deduction under s.80IAB for car-parking rental income was reversed, the tribunal finding no distinguishing facts to deny the incentive. Settlement fees paid on premature termination of service contracts were characterized as revenue expenditure incurred for commercial expediency (not capital acquisition) and allowed. The ITAT therefore ruled in favour of the assessee on the contested adjustments.
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