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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When calculating interest u/s 244A(1), if a refund is granted earlier, it should be adjusted against the interest component first, and the remaining amount, if any, should be adjusted against the principal refund amount. This follows the same methodology as when part taxes are paid by the assessee, where it is first adjusted against the interest payable and then against the tax due. The CIT(A) rightly directed the Assessing Officer to examine the computation of refund, including interest u/s 244A. The impugned order is upheld, and the appeal is dismissed.
When calculating interest u/s 244A(1), if a refund is granted earlier, it should be adjusted against the interest component first, and the remaining amount, if any, should be adjusted against the principal refund amount. This follows the same methodology as when part taxes are paid by the assessee, where it is first adjusted against the interest payable and then against the tax due. The CIT(A) rightly directed the Assessing Officer to examine the computation of refund, including interest u/s 244A. The impugned order is upheld, and the appeal is dismissed.
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