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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The liability to pay the tax arose only in April 2009, but the payment was made in December 2008. Thus the payment made in December 2008, can only be an advance payment of tax and not an excess payment of tax - Adjustment allowed - AT
The liability to pay the tax arose only in April 2009, but the payment was made in December 2008. Thus the payment made in December 2008, can only be an advance payment of tax and not an excess payment of tax - Adjustment allowed - AT
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