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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The Appellate Tribunal addressed the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
The Appellate Tribunal addressed the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
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