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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Deduction of TDS on the amount paid and payable to the workmen - Though it is referred as Voluntary Retirement Scheme, one has to see the object and intent behind it. When once a factual finding is given that it is a special package, a different view is not possible. We may note that the case on hand involves a chequered history with respect to the running of Industry qua rights of the workmen. - Therefore, this is not a case of voluntary retirement by the workmen, but, on the other hand, brought forth by contingency - No TDS liability - HC
Deduction of TDS on the amount paid and payable to the workmen - Though it is referred as Voluntary Retirement Scheme, one has to see the object and intent behind it. When once a factual finding is given that it is a special package, a different view is not possible. We may note that the case on hand involves a chequered history with respect to the running of Industry qua rights of the workmen. - Therefore, this is not a case of voluntary retirement by the workmen, but, on the other hand, brought forth by contingency - No TDS liability - HC
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