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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Work Contract Tax actually paid during the relevant previous year is deductible for an assessee consistently following the cash system of accounting, even where the statutory liability relates to earlier financial years. Once the books and accounting method are accepted, mercantile principles cannot be selectively applied to deny the deduction without material showing a mercantile method, manipulation, or accounting defects warranting intervention. Interest paid solely for delayed payment of Work Contract Tax is compensatory rather than penal in nature. As it compensates the State for delayed use of funds and relates to statutory business liability, the interest is allowable as a business deduction.
Work Contract Tax actually paid during the relevant previous year is deductible for an assessee consistently following the cash system of accounting, even where the statutory liability relates to earlier financial years. Once the books and accounting method are accepted, mercantile principles cannot be selectively applied to deny the deduction without material showing a mercantile method, manipulation, or accounting defects warranting intervention. Interest paid solely for delayed payment of Work Contract Tax is compensatory rather than penal in nature. As it compensates the State for delayed use of funds and relates to statutory business liability, the interest is allowable as a business deduction.
Note: It is a system-generated summary and is for quick reference only.