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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Disallowance of a warranty provision under tax law was contested; ITAT found the provision was based on historical experience and year-wise working, demonstrating obligating events and consistent utilization (warranty utilized Rs.58,05,616). The tribunal rejected revenue's assertion that an adequate opening balance alone eliminated the need for additional provisioning, holding that provisions founded on estimation of obligation and outflow need not be disturbed. Reliance on similar group-entity precedent confirming a scientific basis for warranty provisioning supported allowing the assessee's claim, and the appeal was allowed.
Disallowance of a warranty provision under tax law was contested; ITAT found the provision was based on historical experience and year-wise working, demonstrating obligating events and consistent utilization (warranty utilized Rs.58,05,616). The tribunal rejected revenue's assertion that an adequate opening balance alone eliminated the need for additional provisioning, holding that provisions founded on estimation of obligation and outflow need not be disturbed. Reliance on similar group-entity precedent confirming a scientific basis for warranty provisioning supported allowing the assessee's claim, and the appeal was allowed.
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