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 dismissed the assessee's appeal, upholding the AO's disallowance of deductions claimed under ss. 80GGC/80GGB for donations to a registered unrecognized political party as bogus. The Tribunal accepted the AO's findings that the party's bank accounts were employed by an accommodation-entry operator, with cheque donations layered through multiple accounts and proceeds returned in cash, and that systematic transfers routed funds to a proprietor and onward to traders to legitimize illicit receipts and evade tax. In the absence of any new material or evidence to controvert the detailed enquiry and established transaction trail, the claimed deductions were held to be without merit and rejected.
The ITAT dismissed the assessee's appeal, upholding the AO's disallowance of deductions claimed under ss. 80GGC/80GGB for donations to a registered unrecognized political party as bogus. The Tribunal accepted the AO's findings that the party's bank accounts were employed by an accommodation-entry operator, with cheque donations layered through multiple accounts and proceeds returned in cash, and that systematic transfers routed funds to a proprietor and onward to traders to legitimize illicit receipts and evade tax. In the absence of any new material or evidence to controvert the detailed enquiry and established transaction trail, the claimed deductions were held to be without merit and rejected.
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