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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Unverifiable purchases and unreliable account records justified rejection of books and estimation of gross profit by applying the average gross profit rate of the preceding two years, because the assessee failed to produce primary supporting material and enquiries showed most purchase parties were non-genuine. The addition based on estimated profit was sustained for AY 2021-22. Cash deposited in the bank during the demonetisation period was also treated as unexplained money, as the deposit was verified from bank information and the assessee furnished no supporting evidence for its source. The addition under section 69A was confirmed for AY 2017-18.
Unverifiable purchases and unreliable account records justified rejection of books and estimation of gross profit by applying the average gross profit rate of the preceding two years, because the assessee failed to produce primary supporting material and enquiries showed most purchase parties were non-genuine. The addition based on estimated profit was sustained for AY 2021-22. Cash deposited in the bank during the demonetisation period was also treated as unexplained money, as the deposit was verified from bank information and the assessee furnished no supporting evidence for its source. The addition under section 69A was confirmed for AY 2017-18.
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