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 partly allowed the assessee's appeal. It deleted the disallowance of sales commission paid to certain female agents, holding the AO and CIT(A) had proceeded on assumptions without examining their qualifications, association with the company, and long-standing involvement, and noting that in subsequent years 90% of such commission was allowed on identical facts. ITAT upheld disallowance of the gratuity provision, treating it as a mere provision for gratuity not paid into an approved gratuity fund and therefore not deductible. ITAT also deleted the interest disallowance on advances to a director, finding the assessee possessed sufficient interest-free funds, precluding any notional interest disallowance.
ITAT partly allowed the assessee's appeal. It deleted the disallowance of sales commission paid to certain female agents, holding the AO and CIT(A) had proceeded on assumptions without examining their qualifications, association with the company, and long-standing involvement, and noting that in subsequent years 90% of such commission was allowed on identical facts. ITAT upheld disallowance of the gratuity provision, treating it as a mere provision for gratuity not paid into an approved gratuity fund and therefore not deductible. ITAT also deleted the interest disallowance on advances to a director, finding the assessee possessed sufficient interest-free funds, precluding any notional interest disallowance.
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