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 held that no disallowance can be made in respect of expenditure not claimed by the assessee. As the assessee asserted that no expenditure for the period post 25.03.2017 was debited or claimed, the issue of pro-rata allocation of expenses relating to the slump sale period 25.03.2017 to 31.03.2017 was remanded to the AO for factual verification of both entities' books and audited financials and for fresh adjudication after due hearing. On employees' contribution to PF, ITAT held that payment made on the next working day when the due date fell on a Sunday is deemed timely; the related disallowance was deleted. Disallowances of software expenditure and consultancy fees were confirmed as revenue in nature allowable u/s 37(1), and the Revenue's grounds were rejected.
ITAT held that no disallowance can be made in respect of expenditure not claimed by the assessee. As the assessee asserted that no expenditure for the period post 25.03.2017 was debited or claimed, the issue of pro-rata allocation of expenses relating to the slump sale period 25.03.2017 to 31.03.2017 was remanded to the AO for factual verification of both entities' books and audited financials and for fresh adjudication after due hearing. On employees' contribution to PF, ITAT held that payment made on the next working day when the due date fell on a Sunday is deemed timely; the related disallowance was deleted. Disallowances of software expenditure and consultancy fees were confirmed as revenue in nature allowable u/s 37(1), and the Revenue's grounds were rejected.
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