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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GPA coupled with an agreement to sell resulted in the agent becoming the beneficial owner of the residential plot, so the vendor assessed was not liable for capital gains on the transfer since consideration was received by the beneficial owner. Additions under unexplained expenditure for fuel were deleted after finding fuel costs proportionate to transport receipts and no cogent departmental challenge to books; related addition of Rs. 1,45,16,786 was deleted. Bonus payments recorded in books were sustained as legitimate business expenses. Disallowance for non-deduction of tax on interest paid to banks was deleted on exemption and admitted loan amortization evidence; disallowance for interest to NBFCs may be deleted if those recipients have included and paid tax on the amounts.
GPA coupled with an agreement to sell resulted in the agent becoming the beneficial owner of the residential plot, so the vendor assessed was not liable for capital gains on the transfer since consideration was received by the beneficial owner. Additions under unexplained expenditure for fuel were deleted after finding fuel costs proportionate to transport receipts and no cogent departmental challenge to books; related addition of Rs. 1,45,16,786 was deleted. Bonus payments recorded in books were sustained as legitimate business expenses. Disallowance for non-deduction of tax on interest paid to banks was deleted on exemption and admitted loan amortization evidence; disallowance for interest to NBFCs may be deleted if those recipients have included and paid tax on the amounts.
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