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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Taxability of excess stock discovered on survey: where excess items formed part of undifferentiated total stock discovered before year-end and the assessee admitted and included the amount in the profit and loss account and return, the excess represents undeclared business receipts rather than an identifiable investment. Applying settled authority, the deeming fiction for unexplained investment cannot be invoked for non-identifiable mixed stock and the special tax rate provision does not apply where the amount is offered and accepted as business income. Outcome: appeal allowed; excess stock taxed as business income, not under unexplained investment rules.
Taxability of excess stock discovered on survey: where excess items formed part of undifferentiated total stock discovered before year-end and the assessee admitted and included the amount in the profit and loss account and return, the excess represents undeclared business receipts rather than an identifiable investment. Applying settled authority, the deeming fiction for unexplained investment cannot be invoked for non-identifiable mixed stock and the special tax rate provision does not apply where the amount is offered and accepted as business income. Outcome: appeal allowed; excess stock taxed as business income, not under unexplained investment rules.
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