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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Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
Limitation on carry forward of capital losses was applied: the Tribunal found the assessee did not rebut the revenue's contention or show entitlement to set off a carry forward capital loss beyond the eight succeeding assessment years in which the loss was first computed, and upheld the disallowance of that setoff. On deductibility, the Tribunal treated interest received on enhanced/delayed compensation as income from other sources and held it deductible under the statutory provision governing interest deductions, setting aside the appellate finding and directing the Assessing Officer to allow the deduction accordingly.
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