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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Section 194H applies only where the recipient earns commission or brokerage while acting in a representative capacity for the payer. An online ticketing platform that dealt independently with customers, controlled platform data, bore operational risks, remained liable for platform claims and remitted a fixed ticket amount irrespective of collections operated on a principal-to-principal basis. Its retained convenience fee for digital booking services was therefore not commission paid or constructively paid by the cinema operator, and no tax-deduction obligation arose. Interest for failure to deduct tax was consequential to the primary obligation and was deleted. A separate unchallenged demand remained unaffected.
Section 194H applies only where the recipient earns commission or brokerage while acting in a representative capacity for the payer. An online ticketing platform that dealt independently with customers, controlled platform data, bore operational risks, remained liable for platform claims and remitted a fixed ticket amount irrespective of collections operated on a principal-to-principal basis. Its retained convenience fee for digital booking services was therefore not commission paid or constructively paid by the cinema operator, and no tax-deduction obligation arose. Interest for failure to deduct tax was consequential to the primary obligation and was deleted. A separate unchallenged demand remained unaffected.
Note: It is a system-generated summary and is for quick reference only.