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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Results declared by the assessee in the return were held unsupported by the books of accounts, and the rejection of the books and consequent income estimation was sustained. A cash deposit during the demonetisation period was held to be explained by retail liquor sales and, since sales were accepted as the source and no other unrecorded utilisation appeared, an addition under unexplained money principles was deleted. A claimed deduction under 80C was disallowed for want of documentary proof; absence of supporting evidence before appellate authorities justified upholding that disallowance.
Results declared by the assessee in the return were held unsupported by the books of accounts, and the rejection of the books and consequent income estimation was sustained. A cash deposit during the demonetisation period was held to be explained by retail liquor sales and, since sales were accepted as the source and no other unrecorded utilisation appeared, an addition under unexplained money principles was deleted. A claimed deduction under 80C was disallowed for want of documentary proof; absence of supporting evidence before appellate authorities justified upholding that disallowance.
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