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 u/s 40(a)(i) as assessee not deducted TDS - The Tribunal agreed with the assessee's argument that there was no failure to deduct TDS, as the amounts payable to financial institutions were nil. - ITAT accepted the justification provided by the assessee concerning the percentage completion method as per Accounting Standard AS-7. - Moreover, it accepted the contention that the interest paid was cumulative and claimed as expenditure upon project completion. As a result, the disallowance under section 40(a)(ia) was deemed unwarranted.
Disallowance u/s 40(a)(i) as assessee not deducted TDS - The Tribunal agreed with the assessee's argument that there was no failure to deduct TDS, as the amounts payable to financial institutions were nil. - ITAT accepted the justification provided by the assessee concerning the percentage completion method as per Accounting Standard AS-7. - Moreover, it accepted the contention that the interest paid was cumulative and claimed as expenditure upon project completion. As a result, the disallowance under section 40(a)(ia) was deemed unwarranted.
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