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 examined the denial of concessional tax rate @15% u/s 115BAB to the assessee for A.Ys. 2023-24 and 2024-25, based on application of the fourth proviso to s.115BAB. Observing that the assessee's claim of having duly opted for s.115BAB required factual verification and proper interpretation of the returns, the ITAT held that the first appellate authority must correctly construe the return of income and ensure that the rights of a bona fide assessee are not prejudiced. Consequently, the ITAT set aside the order of the CIT(A)/NFAC and remanded the matter for de novo adjudication, directing a fresh examination of whether the assessee validly exercised the option u/s 115BAB and, if so, determination of eligibility for the concessional tax rate strictly in accordance with law.
The ITAT examined the denial of concessional tax rate @15% u/s 115BAB to the assessee for A.Ys. 2023-24 and 2024-25, based on application of the fourth proviso to s.115BAB. Observing that the assessee's claim of having duly opted for s.115BAB required factual verification and proper interpretation of the returns, the ITAT held that the first appellate authority must correctly construe the return of income and ensure that the rights of a bona fide assessee are not prejudiced. Consequently, the ITAT set aside the order of the CIT(A)/NFAC and remanded the matter for de novo adjudication, directing a fresh examination of whether the assessee validly exercised the option u/s 115BAB and, if so, determination of eligibility for the concessional tax rate strictly in accordance with law.
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