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 addition of deemed rental income where the assessee, owning multiple house properties, failed to prove occupancy or uninhabitability of two properties; applying s. 23(4), the Tribunal confirmed that only one property qualifies as self-occupied and treated the others as deemed let-out, finding the AO's fair-rent estimation based on comparable market data (including property portal information) reasonable in the absence of reliable municipal or rental evidence. On disallowance of housing-loan interest for lack of loan sanction letters and interest certificates, ITAT remitted the issue to the AO for limited verification, granting the assessee an opportunity to produce bank certificates and loan statements and directing the AO to allow deduction as per law upon satisfactory verification.
ITAT upheld the addition of deemed rental income where the assessee, owning multiple house properties, failed to prove occupancy or uninhabitability of two properties; applying s. 23(4), the Tribunal confirmed that only one property qualifies as self-occupied and treated the others as deemed let-out, finding the AO's fair-rent estimation based on comparable market data (including property portal information) reasonable in the absence of reliable municipal or rental evidence. On disallowance of housing-loan interest for lack of loan sanction letters and interest certificates, ITAT remitted the issue to the AO for limited verification, granting the assessee an opportunity to produce bank certificates and loan statements and directing the AO to allow deduction as per law upon satisfactory verification.
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