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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Deduction of interest on borrowed funds for acquisition of a commercial property was denied as business expenditure under s.36(1)(iii) because the assessee failed to establish that the property was acquired for, or actually used in, the assessee's business; the disallowance as business interest was upheld. However, since the property was not occupied for business purposes, its annual value was taxable under the head "Income from House Property," and interest on borrowing for acquisition was in principle deductible under s.24(b) against such annual value; the matter was remanded to the AO to compute annual value under s.23 and allow the corresponding s.24(b) deduction after hearing the assessee. - ITAT
Deduction of interest on borrowed funds for acquisition of a commercial property was denied as business expenditure under s.36(1)(iii) because the assessee failed to establish that the property was acquired for, or actually used in, the assessee's business; the disallowance as business interest was upheld. However, since the property was not occupied for business purposes, its annual value was taxable under the head "Income from House Property," and interest on borrowing for acquisition was in principle deductible under s.24(b) against such annual value; the matter was remanded to the AO to compute annual value under s.23 and allow the corresponding s.24(b) deduction after hearing the assessee. - ITAT
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