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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT held that deduction claimed u/s 80-IA(4) had been allowed by CIT(A) without adequate verification and merely by following the Settlement Commission's order for earlier years, which is under challenge before the HC. ITAT ruled that the assessee is entitled to deduction u/s 80-IA(4) only for those projects that were subject matter of the Settlement Commission proceedings and continued in AYs 2013-14 to 2015-16, subject to verification by the AO. Projects for which the assessee had suo motu withdrawn the claim before CIT(A) are to be disallowed. For all other projects, AO must independently examine contract terms and allow deduction only where they are similar to eligible projects. Revenue's appeals were allowed for statistical purposes and matters remanded to AO.
ITAT held that deduction claimed u/s 80-IA(4) had been allowed by CIT(A) without adequate verification and merely by following the Settlement Commission's order for earlier years, which is under challenge before the HC. ITAT ruled that the assessee is entitled to deduction u/s 80-IA(4) only for those projects that were subject matter of the Settlement Commission proceedings and continued in AYs 2013-14 to 2015-16, subject to verification by the AO. Projects for which the assessee had suo motu withdrawn the claim before CIT(A) are to be disallowed. For all other projects, AO must independently examine contract terms and allow deduction only where they are similar to eligible projects. Revenue's appeals were allowed for statistical purposes and matters remanded to AO.
Note: It is a system-generated summary and is for quick reference only.