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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The Assessing Officer (AO) denied interest u/s 244A for the period from April 2006 to January 2008, citing delay attributable to the assessee in filing the return. The assessee had filed the return on 08/01/2008, after the due date of 30/09/2006. The AO later invoked Section 154 to rectify the alleged mistake of granting excess interest for the 22-month period, assuming jurisdiction erroneously. However, the Tribunal held that such a mistake cannot be rectified u/s 154, as the proposed amendment is effective from 01/06/2016, while the return was filed on 08/01/2008. Additionally, the payer had deducted tax at source, benefiting the revenue irrespective of the return filing date. The refund with interest was granted after the assessee's appeal, and the Coordinate Bench ruled against rectification u/s 154 in similar cases.
The Assessing Officer (AO) denied interest u/s 244A for the period from April 2006 to January 2008, citing delay attributable to the assessee in filing the return. The assessee had filed the return on 08/01/2008, after the due date of 30/09/2006. The AO later invoked Section 154 to rectify the alleged mistake of granting excess interest for the 22-month period, assuming jurisdiction erroneously. However, the Tribunal held that such a mistake cannot be rectified u/s 154, as the proposed amendment is effective from 01/06/2016, while the return was filed on 08/01/2008. Additionally, the payer had deducted tax at source, benefiting the revenue irrespective of the return filing date. The refund with interest was granted after the assessee's appeal, and the Coordinate Bench ruled against rectification u/s 154 in similar cases.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
