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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TDS on accommodation provided by the petitioner to its employees - computation of rent for the purpose of computing perquisites - The respondents had not demanded any quantified amount so that we can direct the department to correct the error, if any. If the petitioner had made an error in computation, it is either by the petitioner to approach the authority for rectification if time is available or for the concerned employees to seek refund of excess deduction of taxes from the salaries. - HC
TDS on accommodation provided by the petitioner to its employees - computation of rent for the purpose of computing perquisites - The respondents had not demanded any quantified amount so that we can direct the department to correct the error, if any. If the petitioner had made an error in computation, it is either by the petitioner to approach the authority for rectification if time is available or for the concerned employees to seek refund of excess deduction of taxes from the salaries. - HC
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