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 held that CSR payments, though disallowed as business expenditure u/s 37(1), may still qualify for deduction u/s 80G when computing total taxable income, subject to statutory conditions, and that denying such deduction would amount to impermissible double disallowance. The issue of quantum and eligibility u/s 80G was remanded to AO for verification. On short-term capital loss from building, ITAT held that allowability depends on whether the sold asset was the sole asset in the relevant block u/s 50, and remanded the matter to AO for factual verification. Deletion by CIT(A) of addition for alleged excess 24KT gold stock was upheld, and Revenue's appeal was dismissed.
ITAT held that CSR payments, though disallowed as business expenditure u/s 37(1), may still qualify for deduction u/s 80G when computing total taxable income, subject to statutory conditions, and that denying such deduction would amount to impermissible double disallowance. The issue of quantum and eligibility u/s 80G was remanded to AO for verification. On short-term capital loss from building, ITAT held that allowability depends on whether the sold asset was the sole asset in the relevant block u/s 50, and remanded the matter to AO for factual verification. Deletion by CIT(A) of addition for alleged excess 24KT gold stock was upheld, and Revenue's appeal was dismissed.
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