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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Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
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