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 under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
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