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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Where reassessment is initiated under s.147 on recorded reasons, the AO must first make an addition on the very issue forming the basis of those reasons; if the AO accepts the explanation and makes no addition on the recorded-reasons issue, no other addition can be made on unrelated matters, and Expln. 3 to s.147 does not cure this defect. Since the AO made no addition regarding the cash deposits referred to in the reasons but instead made an addition under s.40A(3) without any recorded reason, the s.40A(3) addition was held unsustainable and directed to be deleted; the taxpayer's ground was allowed. - ITAT
Where reassessment is initiated under s.147 on recorded reasons, the AO must first make an addition on the very issue forming the basis of those reasons; if the AO accepts the explanation and makes no addition on the recorded-reasons issue, no other addition can be made on unrelated matters, and Expln. 3 to s.147 does not cure this defect. Since the AO made no addition regarding the cash deposits referred to in the reasons but instead made an addition under s.40A(3) without any recorded reason, the s.40A(3) addition was held unsustainable and directed to be deleted; the taxpayer's ground was allowed. - ITAT
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