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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Set off of MAT credit u/s.115JAA - assessee being a company had filed its return of income in ITR-6 (i.e. prescribed form) under schedule for MAT credit (Schedule MATC), the assessee is precluded from filling up any figure as they are automatically picked from yet another schedule in the same ITR form - there is absolutely no scope for ignoring surcharge and education cess for the purpose of computing MAT credit u/s.115JAA of the Act. It is a well known fact that the ITR return form is a form prescribed by CBDT and the revenue is bound to follow the same. - AT
Set off of MAT credit u/s.115JAA - assessee being a company had filed its return of income in ITR-6 (i.e. prescribed form) under schedule for MAT credit (Schedule MATC), the assessee is precluded from filling up any figure as they are automatically picked from yet another schedule in the same ITR form - there is absolutely no scope for ignoring surcharge and education cess for the purpose of computing MAT credit u/s.115JAA of the Act. It is a well known fact that the ITR return form is a form prescribed by CBDT and the revenue is bound to follow the same. - AT
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