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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Penalty u/s 234E - delay in filling of TDS return - Contention of the AR that since the TDS statement pertains to the period i.e for the financial year 2013-14(1st quarter) even though the same has been filed in the year 2017, the Assessing officer is not empowered to levy late filing fees under section 234E unable to be accepted as we find that at the time of processing of the TDS statement i.e. on 14.10.2017, the Assessing officer was empowered to levy such late filing fees, there is no provision to make a distinction between the TDS statements pertaining to period prior to 01.6.2015 and post such period - AT
Penalty u/s 234E - delay in filling of TDS return - Contention of the AR that since the TDS statement pertains to the period i.e for the financial year 2013-14(1st quarter) even though the same has been filed in the year 2017, the Assessing officer is not empowered to levy late filing fees under section 234E unable to be accepted as we find that at the time of processing of the TDS statement i.e. on 14.10.2017, the Assessing officer was empowered to levy such late filing fees, there is no provision to make a distinction between the TDS statements pertaining to period prior to 01.6.2015 and post such period - AT
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