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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Adjustment of part income-tax refund received by the assessee against the total outstanding refund, comprising of principal/ tax and interest - quantum of interest to which the assessee would be entitled u/s 244A - The Tribunal concluded that the part refund should first be adjusted against the interest component of the outstanding refund before adjusting against the principal. This decision aligns with previous rulings from various ITAT benches and the principles of fairness, equity, and good conscience. - The Tribunal discredited the Revenue's argument that this adjustment method would result in granting interest on interest, which is not permissible. It underscored that the adjustment strategy proposed by the assessee does not infringe upon the principles laid down by the Supreme Court.
Adjustment of part income-tax refund received by the assessee against the total outstanding refund, comprising of principal/ tax and interest - quantum of interest to which the assessee would be entitled u/s 244A - The Tribunal concluded that the part refund should first be adjusted against the interest component of the outstanding refund before adjusting against the principal. This decision aligns with previous rulings from various ITAT benches and the principles of fairness, equity, and good conscience. - The Tribunal discredited the Revenue's argument that this adjustment method would result in granting interest on interest, which is not permissible. It underscored that the adjustment strategy proposed by the assessee does not infringe upon the principles laid down by the Supreme Court.
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