Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT allowed the taxpayer's appeal and directed deletion of the disputed addition of Rs.57,21,300 which had been made by CPC and confirmed by the first appellate authority, finding the figure in the initial Form 10B to be an inadvertent arithmetical error corrected by a revised Form 10B (and supporting Form 10BB) reflecting deemed income under section 11(3) of the Act as Rs.2,06,06,960. The Tribunal further accepted the taxpayer's alternative contention that the Form 10B filing requirement cannot be negated by reference to the Rs.5 crore turnover threshold, construing Rule 17B as not subject to that monetary limit, and directed the assessing officer to delete the impugned addition accordingly.
ITAT allowed the taxpayer's appeal and directed deletion of the disputed addition of Rs.57,21,300 which had been made by CPC and confirmed by the first appellate authority, finding the figure in the initial Form 10B to be an inadvertent arithmetical error corrected by a revised Form 10B (and supporting Form 10BB) reflecting deemed income under section 11(3) of the Act as Rs.2,06,06,960. The Tribunal further accepted the taxpayer's alternative contention that the Form 10B filing requirement cannot be negated by reference to the Rs.5 crore turnover threshold, construing Rule 17B as not subject to that monetary limit, and directed the assessing officer to delete the impugned addition accordingly.
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