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 Chapter 80-series was held not forfeited by mere procedural delay in filing Form No.10CCB where the assessees filed the return within the due date and claimed the deduction; the Tribunal treated late filing of the form as a procedural defect, noting the form was uploaded before CPC processing and therefore processing under section 143(1) could not disallow the deduction solely on that ground. The Tribunal set aside the disallowance, directed recomputation of tax on book profits and remitted the matter to the AO for verification of the deduction quantum with opportunity to the assessee.
Deduction under Chapter 80-series was held not forfeited by mere procedural delay in filing Form No.10CCB where the assessees filed the return within the due date and claimed the deduction; the Tribunal treated late filing of the form as a procedural defect, noting the form was uploaded before CPC processing and therefore processing under section 143(1) could not disallow the deduction solely on that ground. The Tribunal set aside the disallowance, directed recomputation of tax on book profits and remitted the matter to the AO for verification of the deduction quantum with opportunity to the assessee.
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