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 allowed the assessee's appeal, deleting additions made u/s 69C and 68. In respect of purchases from the alleged accommodation entry provider, the Tribunal held that the assessee had produced purchase invoices, e-way bills, transport documents, ledger extracts and bank statements evidencing payment through banking channels, and the AO brought no contrary material except a CGST report; the purchases were found to be actually used in manufacturing. For unsecured loans from five creditors, the assessee had filed ITRs, confirmations and bank statements, with no defects identified by AO or CIT(A). Consequently, the CIT(A)'s order was set aside.
ITAT allowed the assessee's appeal, deleting additions made u/s 69C and 68. In respect of purchases from the alleged accommodation entry provider, the Tribunal held that the assessee had produced purchase invoices, e-way bills, transport documents, ledger extracts and bank statements evidencing payment through banking channels, and the AO brought no contrary material except a CGST report; the purchases were found to be actually used in manufacturing. For unsecured loans from five creditors, the assessee had filed ITRs, confirmations and bank statements, with no defects identified by AO or CIT(A). Consequently, the CIT(A)'s order was set aside.
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