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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Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
Assessee sought deduction under section 80JJAA but failed to claim it in the original return and did not file Form 10DA within the prescribed time; the tribunal applied the statutory rule that deductions under Chapter VIA require a claim in the return and concluded that section 80A(5) precludes allowance of deductions not claimed in the return. Because the claim was first made before the CIT(A) and not in the return, the deduction under section 80JJAA was disallowed.
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