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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Genuine share trading transactions executed through a registered broker on the stock exchange, reflected in DEMAT and trading records, and settled through banking channels were held to support allowability of the resulting business loss. The Tribunal held that the loss could not be disallowed merely because the Revenue considered the trades commercially imprudent or compared them with book value, in the absence of material showing artificial loss creation, sham trades, or price manipulation. It further held that SEBI proceedings against company promoters and penny-stock rulings on bogus exempt gains were inapplicable where the assessee's own transactions were genuine trading transactions, and the addition was deleted.
Genuine share trading transactions executed through a registered broker on the stock exchange, reflected in DEMAT and trading records, and settled through banking channels were held to support allowability of the resulting business loss. The Tribunal held that the loss could not be disallowed merely because the Revenue considered the trades commercially imprudent or compared them with book value, in the absence of material showing artificial loss creation, sham trades, or price manipulation. It further held that SEBI proceedings against company promoters and penny-stock rulings on bogus exempt gains were inapplicable where the assessee's own transactions were genuine trading transactions, and the addition was deleted.
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