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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TDS cannot be deducted by the respondent on amounts awarded in favor of the petitioner, a non-resident individual, by an arbitral award under execution. The High Court held that once an amount stands awarded in an arbitral award, it acquires the character of a judgment debt and cannot be subjected to TDS deduction, following Supreme Court precedent in All India Reporter and High Court decisions in Voith Hydro Ltd and Glencore International. The omnibus restraint on deducting TDS in Prateek Infra Projects India Pvt Ltd v. Nidhi Mittal does not amount to a declaration that TDS is deductible on compensation payable to a builder.
TDS cannot be deducted by the respondent on amounts awarded in favor of the petitioner, a non-resident individual, by an arbitral award under execution. The High Court held that once an amount stands awarded in an arbitral award, it acquires the character of a judgment debt and cannot be subjected to TDS deduction, following Supreme Court precedent in All India Reporter and High Court decisions in Voith Hydro Ltd and Glencore International. The omnibus restraint on deducting TDS in Prateek Infra Projects India Pvt Ltd v. Nidhi Mittal does not amount to a declaration that TDS is deductible on compensation payable to a builder.
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