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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Foreign tax credit u/s 91 - Section 6(6) carves out another category of person in ‘Residents’, who is said to be ‘not ordinarily resident’ in India form part of larger group of the persons who are ‘resident’ - section 91 provides relief/deduction of taxes paid with respect to a person who is a ‘resident’ in India - hence credit allowable to resident but not ordinarily resident
Foreign tax credit u/s 91 - Section 6(6) carves out another category of person in ‘Residents’, who is said to be ‘not ordinarily resident’ in India form part of larger group of the persons who are ‘resident’ - section 91 provides relief/deduction of taxes paid with respect to a person who is a ‘resident’ in India - hence credit allowable to resident but not ordinarily resident
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