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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The High Court dealt with multiple MAT computation issues under Section 115JB, applying Apollo Tyres to hold that items not covered by Explanation 1, including foreign corporate tax and deferred revenue expenditure, could not be added back. It also accepted concurrent findings that state capital investment subsidy was a capital receipt, that expenditure on construction of a government-owned road was revenue in nature, and that wealth tax provision was not contemplated under the section. The appeal was admitted only on four issues: sales tax subsidy in book profit, provision for bad and doubtful debts, revenue from trial run production, and withdrawal from share premium account, to be heard with the connected appeal for the earlier year.
The High Court dealt with multiple MAT computation issues under Section 115JB, applying Apollo Tyres to hold that items not covered by Explanation 1, including foreign corporate tax and deferred revenue expenditure, could not be added back. It also accepted concurrent findings that state capital investment subsidy was a capital receipt, that expenditure on construction of a government-owned road was revenue in nature, and that wealth tax provision was not contemplated under the section. The appeal was admitted only on four issues: sales tax subsidy in book profit, provision for bad and doubtful debts, revenue from trial run production, and withdrawal from share premium account, to be heard with the connected appeal for the earlier year.
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