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 upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
ITAT upheld the AO's disallowance of deductions claimed as "impairment of assets" and "abnormal loss" on spares, holding such amounts relate to depreciable fixed assets and are not allowable as revenue expenditure; the Tribunal directed the AO to permit adjustment of those amounts in the relevant block of assets and to allow consequent depreciation. Concurrently, ITAT quashed the penalty under section 270A for misreporting, finding no misrepresentation, suppression, false entry or unsupported claim, and noting absence of requisite findings by the AO; grounds challenging the disallowance were dismissed while the penalty was cancelled.
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