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 partly allowed the assessee's appeal. Disallowance of interest on housing loan under s.24(b) and deduction under s.80C towards principal repayment were upheld as no housing loan certificate or sanction letter was produced. Disallowances on sales promotion, travelling expenses, accounting and consultancy charges, bonus and ex gratia, and addition relating to unexplained capital introduction treated as income from other sources were also confirmed for failure to substantiate genuineness and business nexus. Disallowance of consultancy charges and addition under s.68 towards unsecured loans were set aside to the AO for de novo adjudication. On GST disallowance under s.43B, AO was directed to verify actual payment before return filing; this ground was allowed for statistical purposes.
ITAT partly allowed the assessee's appeal. Disallowance of interest on housing loan under s.24(b) and deduction under s.80C towards principal repayment were upheld as no housing loan certificate or sanction letter was produced. Disallowances on sales promotion, travelling expenses, accounting and consultancy charges, bonus and ex gratia, and addition relating to unexplained capital introduction treated as income from other sources were also confirmed for failure to substantiate genuineness and business nexus. Disallowance of consultancy charges and addition under s.68 towards unsecured loans were set aside to the AO for de novo adjudication. On GST disallowance under s.43B, AO was directed to verify actual payment before return filing; this ground was allowed for statistical purposes.
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