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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Deduction for political donations was contested on grounds that the recipient party was a tainted conduit for accommodation entries; the assessee bore the onus to substantiate genuineness. The assessing officer produced no evidence of commission, reciprocal payments, or a direct nexus showing benefit to the assessee from the recipient party. On that basis the Tribunal affirmed that the addition could not be sustained and decided against the revenue, noting that CIT(A)/NFAC had previously deleted the addition for lack of proof.
Deduction for political donations was contested on grounds that the recipient party was a tainted conduit for accommodation entries; the assessee bore the onus to substantiate genuineness. The assessing officer produced no evidence of commission, reciprocal payments, or a direct nexus showing benefit to the assessee from the recipient party. On that basis the Tribunal affirmed that the addition could not be sustained and decided against the revenue, noting that CIT(A)/NFAC had previously deleted the addition for lack of proof.
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