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 High Court addressed the issue of Tax Deducted at Source u/s 195 and addition u/s 40(a)(ia) for payments made to non-residents. The court examined the scope of Explanation to Section 9(1)(vii) and the retrospective amendment by the Finance Act, 2010. It was held that the retrospective nature of the amendment did not require the Assessee to deduct tax at source. Reference was made to a previous decision accepted by the Department. The court also considered the impossibility of applying certain tax provisions retrospectively. Regarding expenditure on temple repairs and school construction, the court upheld the Tribunal's decision that such expenses were revenue in nature, not requiring deduction of tax at source. The court found no error in the Tribunal's decision and ruled in favor of the assessee.
The High Court addressed the issue of Tax Deducted at Source u/s 195 and addition u/s 40(a)(ia) for payments made to non-residents. The court examined the scope of Explanation to Section 9(1)(vii) and the retrospective amendment by the Finance Act, 2010. It was held that the retrospective nature of the amendment did not require the Assessee to deduct tax at source. Reference was made to a previous decision accepted by the Department. The court also considered the impossibility of applying certain tax provisions retrospectively. Regarding expenditure on temple repairs and school construction, the court upheld the Tribunal's decision that such expenses were revenue in nature, not requiring deduction of tax at source. The court found no error in the Tribunal's decision and ruled in favor of the assessee.
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