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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Alleged embezzlement/misappropriation payments were not allowable as business expenditure because the assessee adopted contradictory characterisations, produced no agreements, bills or particulars identifying the role or benefit to the alleged misappropriator, and did not pursue recovery; the Tribunal's disallowance was sustained. Payments to a partner's relative were disallowed under the provision permitting the assessing officer to strike down excessive or unreasonable related party payments in absence of documentary support; that application was upheld. Reassessment was within limitation because the escaped income exceeded the statutory threshold, bringing the longer limitation period into play; the notice was therefore valid and the appeal dismissed.
Alleged embezzlement/misappropriation payments were not allowable as business expenditure because the assessee adopted contradictory characterisations, produced no agreements, bills or particulars identifying the role or benefit to the alleged misappropriator, and did not pursue recovery; the Tribunal's disallowance was sustained. Payments to a partner's relative were disallowed under the provision permitting the assessing officer to strike down excessive or unreasonable related party payments in absence of documentary support; that application was upheld. Reassessment was within limitation because the escaped income exceeded the statutory threshold, bringing the longer limitation period into play; the notice was therefore valid and the appeal dismissed.
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