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 the appeal for statistical purposes, holding that the CIT(A) exceeded the remit of the proviso to s.251(1)(a) by directing a de novo reassessment when the default related solely to disallowance under s.36(1)(iii). The Tribunal restrained the remand to the discrete issue of s.36(1)(iii) disallowance: it directed deletion of the disallowance insofar as impugned investments fall within the doctrine of commercial expediency and are consistent with prior treatment, and restored remaining investments to the AO for limited verification confined to linkage with interest-free funds and the validity of the s.36(1)(iii) disallowance.
ITAT allowed the appeal for statistical purposes, holding that the CIT(A) exceeded the remit of the proviso to s.251(1)(a) by directing a de novo reassessment when the default related solely to disallowance under s.36(1)(iii). The Tribunal restrained the remand to the discrete issue of s.36(1)(iii) disallowance: it directed deletion of the disallowance insofar as impugned investments fall within the doctrine of commercial expediency and are consistent with prior treatment, and restored remaining investments to the AO for limited verification confined to linkage with interest-free funds and the validity of the s.36(1)(iii) disallowance.
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