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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Revisionary jurisdiction was exercised where the Principal Commissioner found the trust deed empowered the trustee to add any person or charity to the class of beneficiaries, so benefits were not restricted to relatives; accordingly sums received could fall under the chargeable head invoked by the revising officer. The Tribunal agreed that the Assessing Officer failed to verify the genuineness of the trust's claim and did not form an express plausible view, making the AO's order erroneous and prejudicial and justifying revision under the statute; the assessee was given a chance to produce supporting evidence and the appeal was dismissed.
Revisionary jurisdiction was exercised where the Principal Commissioner found the trust deed empowered the trustee to add any person or charity to the class of beneficiaries, so benefits were not restricted to relatives; accordingly sums received could fall under the chargeable head invoked by the revising officer. The Tribunal agreed that the Assessing Officer failed to verify the genuineness of the trust's claim and did not form an express plausible view, making the AO's order erroneous and prejudicial and justifying revision under the statute; the assessee was given a chance to produce supporting evidence and the appeal was dismissed.
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