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 for indexed cost of improvement was allowed in part where documentary proof was incomplete: exercising evaluative discretion, the Tribunal permitted 80% of the improvement cost claimed to be adopted for computing the indexed cost of improvement and directed the assessing officer to recompute and grant the deduction accordingly, setting aside the contrary appellate finding; the Tribunal also condoned the delay in filing the appeal. The operative effect requires the AO to apply 80% of claimed improvement amounts for the specified years and allow corresponding indexed deduction.
Deduction for indexed cost of improvement was allowed in part where documentary proof was incomplete: exercising evaluative discretion, the Tribunal permitted 80% of the improvement cost claimed to be adopted for computing the indexed cost of improvement and directed the assessing officer to recompute and grant the deduction accordingly, setting aside the contrary appellate finding; the Tribunal also condoned the delay in filing the appeal. The operative effect requires the AO to apply 80% of claimed improvement amounts for the specified years and allow corresponding indexed deduction.
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