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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Compensation payable to land losers under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is not subject to income-tax deduction or payment. Tax deducted at source from such compensation is refundable. Where a refund claim is affected by non-filing of the return or delay, the prescribed condonation application and return must be filed to enable processing of the refund. The stated position treats the statutory land-acquisition compensation as outside the scope of taxable income for TDS purposes.
Compensation payable to land losers under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is not subject to income-tax deduction or payment. Tax deducted at source from such compensation is refundable. Where a refund claim is affected by non-filing of the return or delay, the prescribed condonation application and return must be filed to enable processing of the refund. The stated position treats the statutory land-acquisition compensation as outside the scope of taxable income for TDS purposes.
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