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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Credit of TDS - Non-reflection of TDS credit in its 26AS statement - The Appellate Tribunal acknowledged the genuine hardship faced by the appellant - While recognizing the technical constraints, the Tribunal suggests that the Assessing Officer should find a solution to address the appellant's hardship. The Tribunal directs the AO to verify the facts of the case and consider resorting to the provisions of Section 119 of the Income Tax Act, allowing the appellant to address its grievance through proper application.
Credit of TDS - Non-reflection of TDS credit in its 26AS statement - The Appellate Tribunal acknowledged the genuine hardship faced by the appellant - While recognizing the technical constraints, the Tribunal suggests that the Assessing Officer should find a solution to address the appellant's hardship. The Tribunal directs the AO to verify the facts of the case and consider resorting to the provisions of Section 119 of the Income Tax Act, allowing the appellant to address its grievance through proper application.
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