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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Foreign Tax Credit u/s. 90 - denial of tax credit paid in the source country - Form No.67 was not filed before the due date of filing of return of income - While the Tribunal did not directly address the issue of late filing, it emphasized the need for the AO to verify the filing of Form 67 and grant relief accordingly, suggesting a resolution for the delay issue. The Tribunal recognized the discrepancy between the AO's assertion of rejecting the application under Section 154 and the actual allowance of the claim in the order. It directed the AO to rectify this and grant relief if the claim was indeed accepted but not allowed in the final computation.
Foreign Tax Credit u/s. 90 - denial of tax credit paid in the source country - Form No.67 was not filed before the due date of filing of return of income - While the Tribunal did not directly address the issue of late filing, it emphasized the need for the AO to verify the filing of Form 67 and grant relief accordingly, suggesting a resolution for the delay issue. The Tribunal recognized the discrepancy between the AO's assertion of rejecting the application under Section 154 and the actual allowance of the claim in the order. It directed the AO to rectify this and grant relief if the claim was indeed accepted but not allowed in the final computation.
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