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 194I or 194C - storage charges paid by assessee - TDS @ 20% - The ITAT concluded that assessee is liable to deduct Tax at Source u/s 194C - The High court determined that the storage tanks in question did not qualify as land or building under Section 194I of the Act. It concluded that the payments made by the assessee were not subject to tax deduction at source under Section 194I. - The court upheld the decision of the ITAT, disposing of the appeals in favor of the assessee.
TDS u/s 194I or 194C - storage charges paid by assessee - TDS @ 20% - The ITAT concluded that assessee is liable to deduct Tax at Source u/s 194C - The High court determined that the storage tanks in question did not qualify as land or building under Section 194I of the Act. It concluded that the payments made by the assessee were not subject to tax deduction at source under Section 194I. - The court upheld the decision of the ITAT, disposing of the appeals in favor of the assessee.
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