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...
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TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
TDS refunds quantified under an assessment or appellate order under Section 201 constitute a crystallised entitlement carrying statutory interest. Form 26B, which concerns processing and adjustment of TDS statements under Section 200A and Rule 31A, cannot be required for such post-assessment refunds. Outstanding demands may justify withholding or adjustment only through a legally valid order under Section 245; demands linked to the assessee's PAN or sister TANs do not otherwise permit withholding. The quantified refunds were directed to be released with applicable interest, with additional interest for default.
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