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 on account of BSE F&O loss and currency derivative loss. It held that the ex parte interim SEBI order, which formed the sole basis for the AO and CIT(A) to treat the losses as non-genuine, had been set aside and therefore had no binding force. The subsequent SEBI final order related to National Spot Exchange Limited and was held inapplicable to trades executed on the BSE platform. ITAT noted that the assessee had produced contract notes, bank statements, and broker account statements, with no adverse material brought by the Revenue, and held there is no legal bar on routing trades through any stock broker.
ITAT allowed the assessee's appeal, deleting additions on account of BSE F&O loss and currency derivative loss. It held that the ex parte interim SEBI order, which formed the sole basis for the AO and CIT(A) to treat the losses as non-genuine, had been set aside and therefore had no binding force. The subsequent SEBI final order related to National Spot Exchange Limited and was held inapplicable to trades executed on the BSE platform. ITAT noted that the assessee had produced contract notes, bank statements, and broker account statements, with no adverse material brought by the Revenue, and held there is no legal bar on routing trades through any stock broker.
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