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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Addition treating commission receipt as unexplained cash credit was deleted because the AO showed no basis to invoke s.68 and the receipt was from an Indian payer within India, making foreign remittance formalities irrelevant; revenue's ground failed. Addition under s.68 for alleged unexplained investment in a foreign joint venture was deleted since evidence showed the investment was made in FY 2001-02 and was reflected as investment at cost, hence not taxable in the relevant year. Ad hoc disallowance of 10% domestic/foreign travel was deleted for lack of specific defects and absence of cash payments exceeding the alleged threshold. Disallowance of rent paid to a director was deleted as genuineness/business purpose was not in doubt and the recipient offered it to tax. Salary disallowance was deleted based on ledger, bank and TDS evidence. - ITAT
Addition treating commission receipt as unexplained cash credit was deleted because the AO showed no basis to invoke s.68 and the receipt was from an Indian payer within India, making foreign remittance formalities irrelevant; revenue's ground failed. Addition under s.68 for alleged unexplained investment in a foreign joint venture was deleted since evidence showed the investment was made in FY 2001-02 and was reflected as investment at cost, hence not taxable in the relevant year. Ad hoc disallowance of 10% domestic/foreign travel was deleted for lack of specific defects and absence of cash payments exceeding the alleged threshold. Disallowance of rent paid to a director was deleted as genuineness/business purpose was not in doubt and the recipient offered it to tax. Salary disallowance was deleted based on ledger, bank and TDS evidence. - ITAT
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