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 assessee's claim for deduction u/s 10B despite absence of separate books for eligible units, following earlier coordinate bench orders affirmed by Delhi HC, and dismissed Revenue's grounds. In TP, ITAT directed exclusion of specified comparables (Apitco, Cameo Corporate Services, Global Procurement Consultants, Killick Agencies and Marketing, Orient Engineering and Commercial) as functionally dissimilar for the corporate support services segment. ITAT further held, consistent with prior years and Delhi HC/ITAT precedents, that no addition u/s 14A read with Rule 8D is permissible while computing book profits u/s 115JB, and deleted the disallowance u/s 14A for lack of AO's recorded satisfaction. ITAT also permitted enhanced deduction u/s 10B based on suo motu disallowance, holding Goetze (India) inapplicable to appellate powers.
ITAT allowed assessee's claim for deduction u/s 10B despite absence of separate books for eligible units, following earlier coordinate bench orders affirmed by Delhi HC, and dismissed Revenue's grounds. In TP, ITAT directed exclusion of specified comparables (Apitco, Cameo Corporate Services, Global Procurement Consultants, Killick Agencies and Marketing, Orient Engineering and Commercial) as functionally dissimilar for the corporate support services segment. ITAT further held, consistent with prior years and Delhi HC/ITAT precedents, that no addition u/s 14A read with Rule 8D is permissible while computing book profits u/s 115JB, and deleted the disallowance u/s 14A for lack of AO's recorded satisfaction. ITAT also permitted enhanced deduction u/s 10B based on suo motu disallowance, holding Goetze (India) inapplicable to appellate powers.
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