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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HC held that license fees paid by the assessee for use of the goodwill and name of a law firm constitute allowable business expenditure u/s 37. The Court ruled that linking the consideration to a percentage of the firm's billing was merely a computational measure and did not amount to revenue sharing from legal practice. The payment was characterized as consideration for exploitation of goodwill, not a prohibited arrangement under the Advocate's Act or Bar Council of India Rules. Reliance on the SC ruling in Apex Laboratories was rejected as inapposite. Accordingly, the appeals were dismissed and decided in favour of the assessee.
HC held that license fees paid by the assessee for use of the goodwill and name of a law firm constitute allowable business expenditure u/s 37. The Court ruled that linking the consideration to a percentage of the firm's billing was merely a computational measure and did not amount to revenue sharing from legal practice. The payment was characterized as consideration for exploitation of goodwill, not a prohibited arrangement under the Advocate's Act or Bar Council of India Rules. Reliance on the SC ruling in Apex Laboratories was rejected as inapposite. Accordingly, the appeals were dismissed and decided in favour of the assessee.
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