Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Market fee and cess payable under a State enactment are statutory levies, not consideration for contractual work, and therefore do not attract tax deduction at source under the provision governing contractual payments. Government-prescribed procurement payments to societies, supported by sanctioned rates, reimbursement arrangements, control accounts and separately identifiable remuneration, constitute pass-through disbursements rather than contractor or subcontractor expenditure. The related disallowances for non-deduction of tax were deleted. Remission or cessation of a trading liability requires proof of a benefit obtained through an actual waiver, write-back, remission or extinguishment during the relevant year. Outstanding balances, without more, do not establish cessation where liabilities remain recorded, transactions continue and subsequent payments occur; the creditor-liability addition was deleted.
Market fee and cess payable under a State enactment are statutory levies, not consideration for contractual work, and therefore do not attract tax deduction at source under the provision governing contractual payments. Government-prescribed procurement payments to societies, supported by sanctioned rates, reimbursement arrangements, control accounts and separately identifiable remuneration, constitute pass-through disbursements rather than contractor or subcontractor expenditure. The related disallowances for non-deduction of tax were deleted. Remission or cessation of a trading liability requires proof of a benefit obtained through an actual waiver, write-back, remission or extinguishment during the relevant year. Outstanding balances, without more, do not establish cessation where liabilities remain recorded, transactions continue and subsequent payments occur; the creditor-liability addition was deleted.
Note: It is a system-generated summary and is for quick reference only.