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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Gifts from parents and near relatives were accepted as genuine where the recipient disclosed name, address, relationship, quantum and confirming PAN-linked declarations, and the addition was deleted for lack of enquiry or cogent rebuttal by the AO. Cash professional receipts were accepted where the assessee produced client names, income-tax return copies and student IDs for tuition, and the addition was deleted. Cash withdrawals shown in the partnership cashbook and admitted as withdrawals by the partnership were treated as personal withdrawals, not undisclosed income, and the corresponding addition was deleted.
Gifts from parents and near relatives were accepted as genuine where the recipient disclosed name, address, relationship, quantum and confirming PAN-linked declarations, and the addition was deleted for lack of enquiry or cogent rebuttal by the AO. Cash professional receipts were accepted where the assessee produced client names, income-tax return copies and student IDs for tuition, and the addition was deleted. Cash withdrawals shown in the partnership cashbook and admitted as withdrawals by the partnership were treated as personal withdrawals, not undisclosed income, and the corresponding addition was deleted.
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