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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Advances written off may be deductible as business loss where they are made in the ordinary course of business and have a direct nexus with business operations. The Tribunal held that the balance security deposit paid for restaurant premises was a revenue loss because it was advanced for hotel business purposes and remained unrecovered after failed efforts to recover it. It also held that earnest money furnished for joint bidding to secure natural gas for hotel use was a business advance and its forfeiture was allowable as business loss. However, a write-off to an individual treated as a friendly loan, unsupported by evidence of any trade-related purpose, was not deductible and remained disallowed.
Advances written off may be deductible as business loss where they are made in the ordinary course of business and have a direct nexus with business operations. The Tribunal held that the balance security deposit paid for restaurant premises was a revenue loss because it was advanced for hotel business purposes and remained unrecovered after failed efforts to recover it. It also held that earnest money furnished for joint bidding to secure natural gas for hotel use was a business advance and its forfeiture was allowable as business loss. However, a write-off to an individual treated as a friendly loan, unsupported by evidence of any trade-related purpose, was not deductible and remained disallowed.
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