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 section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
Addition under section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
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