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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Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
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