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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Benefit of the VSV Act - The disputed interest is defined under Sub Clause h (ii) of Sub Section 1 of Section 2 to mean “the interest determined in any case under the provisions of the Income Tax Act, 1961 where an appeal has been filed by the appellant in respect of such interest”. - , petitioner was eligible to file this declaration under the VSV Act for the disputed interest that was charged under Section 234A or Section 234B or Section 234C. The concerned authority was, therefore, not correct in rejecting the declaration of petitioner - HC
Benefit of the VSV Act - The disputed interest is defined under Sub Clause h (ii) of Sub Section 1 of Section 2 to mean “the interest determined in any case under the provisions of the Income Tax Act, 1961 where an appeal has been filed by the appellant in respect of such interest”. - , petitioner was eligible to file this declaration under the VSV Act for the disputed interest that was charged under Section 234A or Section 234B or Section 234C. The concerned authority was, therefore, not correct in rejecting the declaration of petitioner - HC
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