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 dismissed both appeals and affirmed the appellate order: the AO's addition under s.69B relating to the cost of cold storage structure was set aside because the CIT(A) properly accepted the DVO's revised valuation report after the DVO considered the assessee's objections, and the minor variation in the revised report did not warrant addition. The CIT(A)'s deletion of the impugned addition was endorsed. With respect to unexplained investment in plant and machinery, the CIT(A)'s decision to uphold the assessment was retained. Consequently, the assessee's appeals are dismissed and the Revenue's appeal is also dismissed.
ITAT dismissed both appeals and affirmed the appellate order: the AO's addition under s.69B relating to the cost of cold storage structure was set aside because the CIT(A) properly accepted the DVO's revised valuation report after the DVO considered the assessee's objections, and the minor variation in the revised report did not warrant addition. The CIT(A)'s deletion of the impugned addition was endorsed. With respect to unexplained investment in plant and machinery, the CIT(A)'s decision to uphold the assessment was retained. Consequently, the assessee's appeals are dismissed and the Revenue's appeal is also dismissed.
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