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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Unexplained cash deposits during demonetisation: the Tribunal held that cash deposited in the bank derived from prior household savings and recorded in the assessee's books, and once receipts are reflected in books and accepted by the assessing officer, the onus to further explain does not sustain an addition under section 69A; consequence - addition under s.69A deleted. Double taxation and prior acceptance of receipts: re-taxing the same receipts under s.69A would amount to double taxation, therefore such duplicate addition is impermissible - consequence - deleted. Evidentiary deficiencies: poor documentary compliance justified partial relief; consequence - a compensatory addition of 10% of Rs.29,60,000 (Rs.2,96,000) sustained. Section 115BBE: deposits held to arise from business and thus not liable to flat rate under s.115BBE; consequence - tax the Rs.2,96,000 at normal rates by the AO. - ITAT
Unexplained cash deposits during demonetisation: the Tribunal held that cash deposited in the bank derived from prior household savings and recorded in the assessee's books, and once receipts are reflected in books and accepted by the assessing officer, the onus to further explain does not sustain an addition under section 69A; consequence - addition under s.69A deleted. Double taxation and prior acceptance of receipts: re-taxing the same receipts under s.69A would amount to double taxation, therefore such duplicate addition is impermissible - consequence - deleted. Evidentiary deficiencies: poor documentary compliance justified partial relief; consequence - a compensatory addition of 10% of Rs.29,60,000 (Rs.2,96,000) sustained. Section 115BBE: deposits held to arise from business and thus not liable to flat rate under s.115BBE; consequence - tax the Rs.2,96,000 at normal rates by the AO. - ITAT
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