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 194C - Addition u/s 201/201(1A) - TDS not deducted from the payments made to contractors under various schemes - The proviso clearly states that nothing contained in subsection (5A)and (5B) shall be applied to a person whose total income is not chargeable to income tax and who does not obtain PAN under any provision of the Act. - the assessee has segregated the contractual payments more than ₹ 5,00,000/- and less than ₹ 5,00,000/- and submitted a statement - CIT(A), in his findings also has observed that where the receipts are more than ₹ 5,00,000/-, the contractors have submitted their returns disclosing the receipts and paid the taxes on the same and hence, it cannot be taxed in the hands of the assessee. - AT
TDS u/s 194C - Addition u/s 201/201(1A) - TDS not deducted from the payments made to contractors under various schemes - The proviso clearly states that nothing contained in subsection (5A)and (5B) shall be applied to a person whose total income is not chargeable to income tax and who does not obtain PAN under any provision of the Act. - the assessee has segregated the contractual payments more than ₹ 5,00,000/- and less than ₹ 5,00,000/- and submitted a statement - CIT(A), in his findings also has observed that where the receipts are more than ₹ 5,00,000/-, the contractors have submitted their returns disclosing the receipts and paid the taxes on the same and hence, it cannot be taxed in the hands of the assessee. - AT
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