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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Disallowance u/s 35 where TDS has been deducted pursuant to section 40 - any claim of expenditure 1st has to cross the threshold of provisions of section 30-38 of the income tax act. If the claim of the expenditure fails that threshold then whether taxes deducted by the assessee or not is immaterial.
Disallowance u/s 35 where TDS has been deducted pursuant to section 40 - any claim of expenditure 1st has to cross the threshold of provisions of section 30-38 of the income tax act. If the claim of the expenditure fails that threshold then whether taxes deducted by the assessee or not is immaterial.
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