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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Credits treated as unexplained cash credits under s.68 were examined to determine whether they were trade advances. Where advances were received from customers (mostly through banking channels) and subsequently adjusted against sales invoices within a reasonable time, the credits were held to be genuine trade advances and not "loan creditors"; hence no enquiry into customer creditworthiness was required and the additions were deleted. Refund of excess labour advance from a goldsmith, recorded against job-work bills and received in cash consistent with trade practice, was held explained and the s.68 addition was deleted. Cash receipts from credit sales were not taxable under s.68 merely for alleged non-collection of TCS since s.206C(1D) was inapplicable due to turnover below s.44AB threshold; addition deleted. Cash deposits during demonetisation were supported by book cash and sales bills; s.69A addition deleted; consequently s.115BBE issue became academic. - ITAT
Credits treated as unexplained cash credits under s.68 were examined to determine whether they were trade advances. Where advances were received from customers (mostly through banking channels) and subsequently adjusted against sales invoices within a reasonable time, the credits were held to be genuine trade advances and not "loan creditors"; hence no enquiry into customer creditworthiness was required and the additions were deleted. Refund of excess labour advance from a goldsmith, recorded against job-work bills and received in cash consistent with trade practice, was held explained and the s.68 addition was deleted. Cash receipts from credit sales were not taxable under s.68 merely for alleged non-collection of TCS since s.206C(1D) was inapplicable due to turnover below s.44AB threshold; addition deleted. Cash deposits during demonetisation were supported by book cash and sales bills; s.69A addition deleted; consequently s.115BBE issue became academic. - ITAT
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