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 considered the levy of late fee u/s 234E for belated filing of quarterly TDS returns. It noted the amendment to section 200A by the Finance Act, 2015, effective from 01.06.2015. Since the assessment years in question were prior to this date, the ITAT held that the Assessing Officer's imposition of late fee u/s 234E while processing TDS returns u/s 200A was unauthorized and invalid. Citing relevant case law, the ITAT ruled that the late fee could not be levied for the financial years 2012-13 and 2013-14. Consequently, the Assessing Officer was directed to remove the late fee imposed u/s 234E in the intimation issued for the processing of quarterly TDS returns. The decision favored the assessee.
The ITAT considered the levy of late fee u/s 234E for belated filing of quarterly TDS returns. It noted the amendment to section 200A by the Finance Act, 2015, effective from 01.06.2015. Since the assessment years in question were prior to this date, the ITAT held that the Assessing Officer's imposition of late fee u/s 234E while processing TDS returns u/s 200A was unauthorized and invalid. Citing relevant case law, the ITAT ruled that the late fee could not be levied for the financial years 2012-13 and 2013-14. Consequently, the Assessing Officer was directed to remove the late fee imposed u/s 234E in the intimation issued for the processing of quarterly TDS returns. The decision favored the assessee.
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