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 the assessee's appeals substantially. Following its own and HC/SC precedents in earlier AYs, ITAT held that each oil well is a separate undertaking eligible for deduction u/s 80IB(9), upheld depreciation on goodwill u/s 32, allowed higher depreciation @ 60% on oil wells/oil fields, and confirmed entitlement to additional depreciation u/s 32(1)(iia). The addition on account of ALP adjustment for HO expense allocation under the Production Sharing Contract was deleted, applying consistency with past accepted practice. Weighted deduction u/s 35(1)(ii) for payment to an ineligible research institution was disallowed. AO was directed to verify and grant MAT credit and full TDS credit as per Form 26AS, and to comply with DRP directions on deduction u/s 42 after fresh adjudication.
ITAT allowed the assessee's appeals substantially. Following its own and HC/SC precedents in earlier AYs, ITAT held that each oil well is a separate undertaking eligible for deduction u/s 80IB(9), upheld depreciation on goodwill u/s 32, allowed higher depreciation @ 60% on oil wells/oil fields, and confirmed entitlement to additional depreciation u/s 32(1)(iia). The addition on account of ALP adjustment for HO expense allocation under the Production Sharing Contract was deleted, applying consistency with past accepted practice. Weighted deduction u/s 35(1)(ii) for payment to an ineligible research institution was disallowed. AO was directed to verify and grant MAT credit and full TDS credit as per Form 26AS, and to comply with DRP directions on deduction u/s 42 after fresh adjudication.
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