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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Deduction under section 35(1)(ii) was denied because the recipient trust lacked valid recognition beyond 31.03.2006 and post 2006 certificates/receipts were treated as forged or invalid; ITAT upheld disallowance, endorsing the Commissioner(Appeals) reliance on CBDT instructions and precedent. Separately, weighted deductions under section 80 IA for an effluent treatment plant and steam generation were refused for failure to furnish the statutory audit report/Form 10CCB within the prescribed period; ITAT applied the principle of strict/substantial compliance of fiscal formalities and held the conditions precedent unmet, so deductions could not be allowed. Appeals dismissed on both grounds.
Deduction under section 35(1)(ii) was denied because the recipient trust lacked valid recognition beyond 31.03.2006 and post 2006 certificates/receipts were treated as forged or invalid; ITAT upheld disallowance, endorsing the Commissioner(Appeals) reliance on CBDT instructions and precedent. Separately, weighted deductions under section 80 IA for an effluent treatment plant and steam generation were refused for failure to furnish the statutory audit report/Form 10CCB within the prescribed period; ITAT applied the principle of strict/substantial compliance of fiscal formalities and held the conditions precedent unmet, so deductions could not be allowed. Appeals dismissed on both grounds.
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