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 two issues regarding TDS credit. Firstly, the Tribunal emphasized that income and TDS must align in any assessment year when income is accrued to the assessee. Therefore, TDS credit cannot be isolated without corresponding income for taxation. The matter was remitted to the Assessing Officer for reconsideration. Secondly, the Tribunal clarified that TDS credit should be available in the year the income is reported, as per Section 199(3) and Rule 37BA(3). The Tribunal directed that the assessee is entitled to TDS credit in the Assessment Year 2017-18 if certain conditions are met, ensuring no double claiming of credit. The decision of the CIT(A) was set aside, and the case was sent back to the Assessing Officer for granting TDS credit in the specified assessment year.
The Appellate Tribunal addressed two issues regarding TDS credit. Firstly, the Tribunal emphasized that income and TDS must align in any assessment year when income is accrued to the assessee. Therefore, TDS credit cannot be isolated without corresponding income for taxation. The matter was remitted to the Assessing Officer for reconsideration. Secondly, the Tribunal clarified that TDS credit should be available in the year the income is reported, as per Section 199(3) and Rule 37BA(3). The Tribunal directed that the assessee is entitled to TDS credit in the Assessment Year 2017-18 if certain conditions are met, ensuring no double claiming of credit. The decision of the CIT(A) was set aside, and the case was sent back to the Assessing Officer for granting TDS credit in the specified assessment year.
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