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 the assessee's provision for mine closure/restoration expenses, computed on a scientific basis and deposited in an escrow account pursuant to an approved Mine Closure Plan, is allowable as a deductible provision, consistent with the Tribunal's decision in the assessee's own case for the preceding year. Finding no distinguishing facts, ITAT directed the AO to allow the assessee's claim for provision of Rs. 80.10 crores towards mine restoration expenses. However, the separate claim of Rs. 9.61 crores as expenditure u/s 43B was directed to be disallowed, in line with the earlier year's ruling. Consequently, both the Revenue's appeals and the assessee's cross-objections were allowed.
ITAT held that the assessee's provision for mine closure/restoration expenses, computed on a scientific basis and deposited in an escrow account pursuant to an approved Mine Closure Plan, is allowable as a deductible provision, consistent with the Tribunal's decision in the assessee's own case for the preceding year. Finding no distinguishing facts, ITAT directed the AO to allow the assessee's claim for provision of Rs. 80.10 crores towards mine restoration expenses. However, the separate claim of Rs. 9.61 crores as expenditure u/s 43B was directed to be disallowed, in line with the earlier year's ruling. Consequently, both the Revenue's appeals and the assessee's cross-objections were allowed.
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