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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Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
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