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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Refund of excess dividend distribution tax - it is not in dispute that the wholly owned subsidiary company had duly remitted the dividend distribution tax on the interim dividend declared by it to the assessee company. - the action of the lower authorities in the instant case is clearly contrary to the provisions of Section 115O(1A) - we hold that assessee is entitled as per the Act to seek refund in respect of excess payment of dividend distribution tax. - AT
Refund of excess dividend distribution tax - it is not in dispute that the wholly owned subsidiary company had duly remitted the dividend distribution tax on the interim dividend declared by it to the assessee company. - the action of the lower authorities in the instant case is clearly contrary to the provisions of Section 115O(1A) - we hold that assessee is entitled as per the Act to seek refund in respect of excess payment of dividend distribution tax. - AT
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