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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Transfer of passive infrastructure assets pursuant to a court-approved demerger was held to constitute a "gift" covered by section 47(iii) and therefore not a "transfer" under section 2(47), negating the Revenue's case for depreciation-related disallowance; the Revenue's ground was dismissed. Network site rentals disallowed as excessive under section 40A(2)(b) were restored for de novo examination due to lack of factual inquiry into cost/value basis; remand ordered. Disallowance under section 14A was deleted as no exempt income was earned. Roaming charge disallowance under sections 40(a)(ia)/40(a)(i) for alleged TDS default was deleted, following binding precedent. Trade discounts on prepaid distribution were held outside section 194H; disallowance deleted. Multiple section 80IA claims (including SFIS income and allied receipts) were allowed applying section 80IA(2A), while variable license fee treatment was directed to be recomputed on amortisation after verification. Book profit under section 115JB was to be computed without importing Rule 8D. - ITAT
Transfer of passive infrastructure assets pursuant to a court-approved demerger was held to constitute a "gift" covered by section 47(iii) and therefore not a "transfer" under section 2(47), negating the Revenue's case for depreciation-related disallowance; the Revenue's ground was dismissed. Network site rentals disallowed as excessive under section 40A(2)(b) were restored for de novo examination due to lack of factual inquiry into cost/value basis; remand ordered. Disallowance under section 14A was deleted as no exempt income was earned. Roaming charge disallowance under sections 40(a)(ia)/40(a)(i) for alleged TDS default was deleted, following binding precedent. Trade discounts on prepaid distribution were held outside section 194H; disallowance deleted. Multiple section 80IA claims (including SFIS income and allied receipts) were allowed applying section 80IA(2A), while variable license fee treatment was directed to be recomputed on amortisation after verification. Book profit under section 115JB was to be computed without importing Rule 8D. - ITAT
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