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 ss. 69 and 69C for alleged unexplained investment and expenditure in purchase of immovable property held jointly with the assessee's parent was unsustainable because the assessee established the source of funds as amounts received from the other parent's accumulated salary and pension savings, and the revenue failed to rebut this explanation. The absence of old retirement documents was not treated as fatal given the long lapse of time since retirement and the availability of fund-utilization details for the purchase consideration and incidental expenses. The additions were directed to be deleted and the appeal was allowed - ITAT
Addition under ss. 69 and 69C for alleged unexplained investment and expenditure in purchase of immovable property held jointly with the assessee's parent was unsustainable because the assessee established the source of funds as amounts received from the other parent's accumulated salary and pension savings, and the revenue failed to rebut this explanation. The absence of old retirement documents was not treated as fatal given the long lapse of time since retirement and the availability of fund-utilization details for the purchase consideration and incidental expenses. The additions were directed to be deleted and the appeal was allowed - ITAT
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