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 Central Board of Direct Taxes issues a corrigendum to its letter dated 21.10.2025 concerning the C&AG Performance Audit Report No. 1 of 2019 on assessment of assessees in the entertainment sector, specifically regarding verification of expenses. The corrigendum clarifies that paragraph 2.1 of the earlier letter incorrectly referred to section 32D of the Income-tax Act, 1961, and should instead refer to section 35D. It instructs that pre-operative expenses incurred before commencement of business by entertainment sector assessees be examined with reference to actual commencement and allowed for amortisation under section 35D. The correction is issued with competent authority approval.
The Central Board of Direct Taxes issues a corrigendum to its letter dated 21.10.2025 concerning the C&AG Performance Audit Report No. 1 of 2019 on assessment of assessees in the entertainment sector, specifically regarding verification of expenses. The corrigendum clarifies that paragraph 2.1 of the earlier letter incorrectly referred to section 32D of the Income-tax Act, 1961, and should instead refer to section 35D. It instructs that pre-operative expenses incurred before commencement of business by entertainment sector assessees be examined with reference to actual commencement and allowed for amortisation under section 35D. The correction is issued with competent authority approval.
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