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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An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
An aborted IPO expenditure was treated as revenue expenditure allowable under section 37(1) because no asset came into existence and no enduring benefit was obtained. Receipts from foreign exchange differences and write-back of provisions were held to have a direct first-degree nexus with the export business of the 100% export-oriented unit, so section 10B deduction was allowed. Product development /expenses were not permitted to be spread as deferred revenue expenditure in the absence of statutory basis. Section 14A disallowance was confined to the exempt income earned. Loss on forward contracts entered into to hedge business exposure was held to be normal business loss, not speculation loss.
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