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 based on undisclosed income allegedly admitted during survey u/s 133A was deleted because the Revenue produced no substantive corroborative evidence, and a survey statement, particularly when promptly retracted and alleged to be obtained under coercion, lacks evidentiary value; reliance was placed on binding precedent holding that no addition can rest solely on such statement, supported by CBDT instructions to rely on material evidence, resulting in dismissal of the Revenue's ground. Disallowance u/s 40A(3) was upheld only to the extent sustained by the first appellate authority since detailed expense-wise verification showed certain payments were made through account payee cheque and the appellate findings disclosed no infirmity, leading to rejection of the Revenue's challenge. - ITAT
Addition based on undisclosed income allegedly admitted during survey u/s 133A was deleted because the Revenue produced no substantive corroborative evidence, and a survey statement, particularly when promptly retracted and alleged to be obtained under coercion, lacks evidentiary value; reliance was placed on binding precedent holding that no addition can rest solely on such statement, supported by CBDT instructions to rely on material evidence, resulting in dismissal of the Revenue's ground. Disallowance u/s 40A(3) was upheld only to the extent sustained by the first appellate authority since detailed expense-wise verification showed certain payments were made through account payee cheque and the appellate findings disclosed no infirmity, leading to rejection of the Revenue's challenge. - ITAT
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