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 affirmed the First Appellate Authority: the assessee's claim of exemption under sections 10(34) and 10(35) was held admissible; the cancellation of registration under section 12A for FY 2014-15 precluded claim under section 11, rendering the dividend and unit income exempt under 10(34)/10(35). Alleged contravention of sections 13(1)(d) and 13(2)(h) was rejected because the impugned investment constituted accretion of bonus shares and did not attract section 13(1)(d). Claims for deduction under section 80G/80GGA were remitted to the AO for verification and allowance to entities registered under section 80G(3)(a)(iiif) in accordance with section 80G(4).
The ITAT affirmed the First Appellate Authority: the assessee's claim of exemption under sections 10(34) and 10(35) was held admissible; the cancellation of registration under section 12A for FY 2014-15 precluded claim under section 11, rendering the dividend and unit income exempt under 10(34)/10(35). Alleged contravention of sections 13(1)(d) and 13(2)(h) was rejected because the impugned investment constituted accretion of bonus shares and did not attract section 13(1)(d). Claims for deduction under section 80G/80GGA were remitted to the AO for verification and allowance to entities registered under section 80G(3)(a)(iiif) in accordance with section 80G(4).
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