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 claimed as cessation of liability for alleged non existent sundry creditors was examined where the AO had accepted increased purchases, sales and consequent creditor balances and prior years' assessments similarly accepted such creditors. The tribunal found sample based non verification of 29.24% of creditors insufficient to displace accepted trading results, and relied on higher court precedents to hold that no addition under cessation of liability principles was warranted. The AO's addition was deleted and the tax effect reversed in favour of the assessee.
Addition claimed as cessation of liability for alleged non existent sundry creditors was examined where the AO had accepted increased purchases, sales and consequent creditor balances and prior years' assessments similarly accepted such creditors. The tribunal found sample based non verification of 29.24% of creditors insufficient to displace accepted trading results, and relied on higher court precedents to hold that no addition under cessation of liability principles was warranted. The AO's addition was deleted and the tax effect reversed in favour of the assessee.
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