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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The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
Note: It is a system-generated summary and is for quick reference only.