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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Interest liability accrued on a soft loan advanced by the State Government under an agreement was disallowed as an unascertained liability under section 37. Applying the mercantile system, interest became payable and had to be provided in the accounts notwithstanding that repayment had not commenced due to non-withdrawal of the full sanctioned amount. Since the loan was admittedly obtained and interest was contractually chargeable, the interest provision constituted an ascertained liability and could not be disallowed under section 37. The deduction for interest so provided was directed to be allowed, and the appeal was allowed. - ITAT
Interest liability accrued on a soft loan advanced by the State Government under an agreement was disallowed as an unascertained liability under section 37. Applying the mercantile system, interest became payable and had to be provided in the accounts notwithstanding that repayment had not commenced due to non-withdrawal of the full sanctioned amount. Since the loan was admittedly obtained and interest was contractually chargeable, the interest provision constituted an ascertained liability and could not be disallowed under section 37. The deduction for interest so provided was directed to be allowed, and the appeal was allowed. - ITAT
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