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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When a filed return is selected for scrutiny, the scope is ordinarily limited to verifying and disallowing claims and does not permit the Assessing Officer to reduce income voluntarily admitted by the taxpayer; statutory remedies exist to correct any erroneous admission but were not availed here. Circulars relied upon did not require reversion of a voluntarily declared return. A post-survey voluntary declaration incorporated in a later return and not retracted or revised under the Act was treated as conscious admission; the burden to prove evidentiary basis does not shift to the Assessing Officer. Tribunal factual findings upheld; taxpayer appeal dismissed.
When a filed return is selected for scrutiny, the scope is ordinarily limited to verifying and disallowing claims and does not permit the Assessing Officer to reduce income voluntarily admitted by the taxpayer; statutory remedies exist to correct any erroneous admission but were not availed here. Circulars relied upon did not require reversion of a voluntarily declared return. A post-survey voluntary declaration incorporated in a later return and not retracted or revised under the Act was treated as conscious admission; the burden to prove evidentiary basis does not shift to the Assessing Officer. Tribunal factual findings upheld; taxpayer appeal dismissed.
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