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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In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
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