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 challenging deletion of addition u/s 68 r.w.s. 115BBE on account of alleged bogus unsecured loan. The CIT(A), after conducting independent inquiries, found that the lender company possessed adequate creditworthiness and that the transaction was genuine, thus satisfying the conditions of s.68. The Revenue failed to rebut these factual findings or produce contrary material. ITAT upheld the CIT(A)'s conclusion that the loan of INR 25 lakhs could not be treated as unexplained cash credit. Consequently, the corresponding disallowance of interest on such loan was also set aside and allowed as deductible business expenditure.
ITAT dismissed the Revenue's appeal challenging deletion of addition u/s 68 r.w.s. 115BBE on account of alleged bogus unsecured loan. The CIT(A), after conducting independent inquiries, found that the lender company possessed adequate creditworthiness and that the transaction was genuine, thus satisfying the conditions of s.68. The Revenue failed to rebut these factual findings or produce contrary material. ITAT upheld the CIT(A)'s conclusion that the loan of INR 25 lakhs could not be treated as unexplained cash credit. Consequently, the corresponding disallowance of interest on such loan was also set aside and allowed as deductible business expenditure.
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