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 ITAT held that the assessee must reconcile differences in TDS amounts between Form No. 26AS and books of accounts. The matter was sent back to AO for further enquiry. Disallowance u/s. 35AC was rejected as donor's deduction cannot be denied for recipient's misuse of funds. Disallowance of guarantee commission was deleted as AO failed to justify the disallowance. Short credit of TDS was allowed upon verification by AO. Interest u/s. 234A was disputed due to extended filing date, following a High Court directive to not charge interest if tax was paid by original due date.
The ITAT held that the assessee must reconcile differences in TDS amounts between Form No. 26AS and books of accounts. The matter was sent back to AO for further enquiry. Disallowance u/s. 35AC was rejected as donor's deduction cannot be denied for recipient's misuse of funds. Disallowance of guarantee commission was deleted as AO failed to justify the disallowance. Short credit of TDS was allowed upon verification by AO. Interest u/s. 234A was disputed due to extended filing date, following a High Court directive to not charge interest if tax was paid by original due date.
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