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 u/s 194A - assessee in default for non-deduction of TDS - Onus upon the assessee to furnish the CA certificates that the payee has paid necessary taxes on income credited by the assessee. However in the case on hand the assessee has submitted PAN of the payee and claimed that the payee has filed income tax return for the year dated 13-07-2009 - None of the authorities below verified the genuineness of the claim of the assessee. We are of the view that the proviso to section 201(1) in beneficial in nature hence the same should be applied in liberal manner - Matter restored back - AT
TDS u/s 194A - assessee in default for non-deduction of TDS - Onus upon the assessee to furnish the CA certificates that the payee has paid necessary taxes on income credited by the assessee. However in the case on hand the assessee has submitted PAN of the payee and claimed that the payee has filed income tax return for the year dated 13-07-2009 - None of the authorities below verified the genuineness of the claim of the assessee. We are of the view that the proviso to section 201(1) in beneficial in nature hence the same should be applied in liberal manner - Matter restored back - AT
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