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 allowed in part the Department's appeals regarding admissibility of a statement recorded during search, finding the assessee failed to prove duress in retraction; grounds 1-7 of the Department's appeal were allowed. However, the Tribunal upheld the CIT(A)'s deletions of additions based on documents seized from a third party's premises, holding no corroborative link to the assessee's books. An extrapolated addition for under-invoicing was curtailed and quantified at Rs.2.419 per kg for 230,407.20 kg supplied to a specified purchaser; wholesale extrapolation was disapproved. Additions under ss.69A and 69C were deleted. The Tribunal disallowed an enhancement of GP to 24%, allowed deduction under s.80IA for captive steam generation, and held the s.153A assessment unsustainable as not founded on incriminating material.
The ITAT allowed in part the Department's appeals regarding admissibility of a statement recorded during search, finding the assessee failed to prove duress in retraction; grounds 1-7 of the Department's appeal were allowed. However, the Tribunal upheld the CIT(A)'s deletions of additions based on documents seized from a third party's premises, holding no corroborative link to the assessee's books. An extrapolated addition for under-invoicing was curtailed and quantified at Rs.2.419 per kg for 230,407.20 kg supplied to a specified purchaser; wholesale extrapolation was disapproved. Additions under ss.69A and 69C were deleted. The Tribunal disallowed an enhancement of GP to 24%, allowed deduction under s.80IA for captive steam generation, and held the s.153A assessment unsustainable as not founded on incriminating material.
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