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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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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TDS credit for rental income remains available where the tenant has actually deducted tax but fails to deposit it with the Central Government. Actual deduction triggers statutory protection against a direct tax demand on the income recipient; the deductor's deposit default cannot undermine the recipient's income declaration or justify withholding credit. Recovery of the unpaid tax must be pursued against the tenant-deductor. Credit for tax deducted from rental income was therefore directed to be granted, and the appeal was allowed.
TDS credit for rental income remains available where the tenant has actually deducted tax but fails to deposit it with the Central Government. Actual deduction triggers statutory protection against a direct tax demand on the income recipient; the deductor's deposit default cannot undermine the recipient's income declaration or justify withholding credit. Recovery of the unpaid tax must be pursued against the tenant-deductor. Credit for tax deducted from rental income was therefore directed to be granted, and the appeal was allowed.
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