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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Disallowing interest expenses u/s. 40(a)(ia) - tax deducted at source (TDS) was not deposited - No disallowance u/s. 40(a)(ia) is warranted as the payee has accounted for the interest income in its Books of Accounts and filed its return of income u/s. 139(1) of the Act. However, since the information filed by the assessee showing that the payee had accounted for the interest receipts in its Books of Accounts and paid taxes, were never examined by the lower authorities, subject to verification of these evidences by the Assessing Officer, we direct to delete the disallowance made u/s. 40(a)(ia) of the Act. - AT
Disallowing interest expenses u/s. 40(a)(ia) - tax deducted at source (TDS) was not deposited - No disallowance u/s. 40(a)(ia) is warranted as the payee has accounted for the interest income in its Books of Accounts and filed its return of income u/s. 139(1) of the Act. However, since the information filed by the assessee showing that the payee had accounted for the interest receipts in its Books of Accounts and paid taxes, were never examined by the lower authorities, subject to verification of these evidences by the Assessing Officer, we direct to delete the disallowance made u/s. 40(a)(ia) of the Act. - AT
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