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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Disallowance of TDS on account of mismatch & later on TDS matched but AO not given credit - Although the rectification application was filed beyond the permissible time limit, the Tribunal invoked Section 155, which empowers the AO to rectify apparent errors in credit of taxes. Considering the appellant's efforts to rectify the TDS credit and the genuineness of the tax credit denied by the AO, the Tribunal directed the AO to pass a consequential order granting the tax credit due to the appellant.
Disallowance of TDS on account of mismatch & later on TDS matched but AO not given credit - Although the rectification application was filed beyond the permissible time limit, the Tribunal invoked Section 155, which empowers the AO to rectify apparent errors in credit of taxes. Considering the appellant's efforts to rectify the TDS credit and the genuineness of the tax credit denied by the AO, the Tribunal directed the AO to pass a consequential order granting the tax credit due to the appellant.
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