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 was initiated within four years, the AO was not required to quantify the alleged escapement in the recorded reasons; reopening to verify impugned transactions was therefore valid. Consequently, the assessee's objection that no addition could be made for purchases from one of the concerned vendors on the ground that such transactions were outside the reopening reasons was rejected, and the AO was held competent to examine and make additions on those purchases. On the genuineness of such purchases and the appropriate disallowance, profit was directed to be estimated at 5% higher than the GP rate disclosed for the year, after granting opportunity of hearing, resulting in partial relief. - ITAT
Where reassessment was initiated within four years, the AO was not required to quantify the alleged escapement in the recorded reasons; reopening to verify impugned transactions was therefore valid. Consequently, the assessee's objection that no addition could be made for purchases from one of the concerned vendors on the ground that such transactions were outside the reopening reasons was rejected, and the AO was held competent to examine and make additions on those purchases. On the genuineness of such purchases and the appropriate disallowance, profit was directed to be estimated at 5% higher than the GP rate disclosed for the year, after granting opportunity of hearing, resulting in partial relief. - ITAT
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