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 liability u/s 194C - 'Contract for Sale' and not a 'Works Contract' - Scope of the term "Work" - Seeking issue a Certificate u/s 197 r.w.s. 206(C)(9) for NIL Tax Deduction at Source (TDS) on all sales effected by the Petitioner/ Company - The burden of proof regarding the nature of transactions between the assessee and Hindustan Lever Limited (HUL) falls on the assessee. The court emphasizes the importance of providing sufficient documentation to support the claim that the transactions do not fall under Section 194C but rather under a different category, such as a contract for sale. - Ultimately, the court disposes of the writ petitions, indicating that the petitioner's claims are not legally tenable given their past treatment of payments from HUL and the lack of documents disputing the tax deductions made by HUL.
TDS liability u/s 194C - 'Contract for Sale' and not a 'Works Contract' - Scope of the term "Work" - Seeking issue a Certificate u/s 197 r.w.s. 206(C)(9) for NIL Tax Deduction at Source (TDS) on all sales effected by the Petitioner/ Company - The burden of proof regarding the nature of transactions between the assessee and Hindustan Lever Limited (HUL) falls on the assessee. The court emphasizes the importance of providing sufficient documentation to support the claim that the transactions do not fall under Section 194C but rather under a different category, such as a contract for sale. - Ultimately, the court disposes of the writ petitions, indicating that the petitioner's claims are not legally tenable given their past treatment of payments from HUL and the lack of documents disputing the tax deductions made by HUL.
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