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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Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
Note: It is a system-generated summary and is for quick reference only.