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 dismissed the Revenue's appeal and upheld the deletion of addition u/s 68 r.w.s. 115BBE on cash deposits of specified bank notes during demonetisation. The Tribunal held that the impugned cash deposits represented recorded sales already credited to the Profit & Loss account, duly reflected in audited books and VAT/Sales Tax returns, with no rejection of books or discrepancy in sales, purchases or stock by the AO. Since the sales were accepted as genuine and payments for purchases were routed through banking channels, invoking s.68 would result in impermissible double addition. The order of CIT(A) deleting the addition was affirmed.
ITAT dismissed the Revenue's appeal and upheld the deletion of addition u/s 68 r.w.s. 115BBE on cash deposits of specified bank notes during demonetisation. The Tribunal held that the impugned cash deposits represented recorded sales already credited to the Profit & Loss account, duly reflected in audited books and VAT/Sales Tax returns, with no rejection of books or discrepancy in sales, purchases or stock by the AO. Since the sales were accepted as genuine and payments for purchases were routed through banking channels, invoking s.68 would result in impermissible double addition. The order of CIT(A) deleting the addition was affirmed.
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