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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Agricultural income was partly disallowed because the taxpayer failed to substantiate cultivation and entitlement to agricultural income from land owned by a sibling; a bare assertion and sibling confirmation, without corroboration such as evidence that the sibling did not declare such income, was held insufficient, so agricultural income was accepted only proportionately to the taxpayer's own land and the balance was assessed as income from other sources. Reassessment under s.147 to tax unsecured loans under s.68 was invalid since the issue had been specifically examined in the original scrutiny and accepted, making reopening a mere change of opinion; the election affidavit disclosed no adverse new material and there was no fresh loan receipt during the year, so jurisdiction failed and the addition was deleted. - ITAT
Agricultural income was partly disallowed because the taxpayer failed to substantiate cultivation and entitlement to agricultural income from land owned by a sibling; a bare assertion and sibling confirmation, without corroboration such as evidence that the sibling did not declare such income, was held insufficient, so agricultural income was accepted only proportionately to the taxpayer's own land and the balance was assessed as income from other sources. Reassessment under s.147 to tax unsecured loans under s.68 was invalid since the issue had been specifically examined in the original scrutiny and accepted, making reopening a mere change of opinion; the election affidavit disclosed no adverse new material and there was no fresh loan receipt during the year, so jurisdiction failed and the addition was deleted. - ITAT
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