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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Depreciation on goodwill arising from an amalgamation is not allowable where the goodwill was not capitalised or brought into the relevant block of intangible assets, because depreciation operates through the block-of-assets mechanism and requires recognition of actual cost and opening written down value; consequence: the goodwill claim is rejected. Separately, denial of intra-year set-off of losses of a SEZ unit was remitted for factual verification since explanation permitting depreciation despite non-claim applies and the assessing officer must examine existence of depreciable assets, business use and WDV; consequence: the Dahej unit claim is sent back for verification and recomputation after hearing the assessee.
Depreciation on goodwill arising from an amalgamation is not allowable where the goodwill was not capitalised or brought into the relevant block of intangible assets, because depreciation operates through the block-of-assets mechanism and requires recognition of actual cost and opening written down value; consequence: the goodwill claim is rejected. Separately, denial of intra-year set-off of losses of a SEZ unit was remitted for factual verification since explanation permitting depreciation despite non-claim applies and the assessing officer must examine existence of depreciable assets, business use and WDV; consequence: the Dahej unit claim is sent back for verification and recomputation after hearing the assessee.
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