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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Assessment of whether provisions for gratuity and leave encashment qualify as application of income under the trust exemption. The Tribunal held such provisions are mandated by law, represent accrued and crystallized liabilities as on the balance sheet date, and are required for a true and fair view; it drew an analogy with depreciation as a book entry reflecting correct profits. The expression "applied" must be read commercially to include necessary statutory provisions incurred in furtherance of trust objects. Consequently the Assessing Officer was directed to allow these provisions as application of income and revenue grounds were dismissed.
Assessment of whether provisions for gratuity and leave encashment qualify as application of income under the trust exemption. The Tribunal held such provisions are mandated by law, represent accrued and crystallized liabilities as on the balance sheet date, and are required for a true and fair view; it drew an analogy with depreciation as a book entry reflecting correct profits. The expression "applied" must be read commercially to include necessary statutory provisions incurred in furtherance of trust objects. Consequently the Assessing Officer was directed to allow these provisions as application of income and revenue grounds were dismissed.
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