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 liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
The liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
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