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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Discretionary trust liable to pay tax at maximum marginal rate, including highest slab rate of income tax and surcharge applicable to individuals. Section 2(29C) mandates computing maximum marginal rate by considering highest tax rate and surcharge rate for individuals. Surcharge cannot be based on trust's slab rate; it defeats the purpose of discouraging discretionary trusts. Central Processing Centre has power u/s 143(1) to compute correct tax and surcharge amount payable by assessee. Assessee's appeal dismissed, upholding CIT(A)'s order that maximum marginal rate is correctly computed using highest individual tax and surcharge rates.
Discretionary trust liable to pay tax at maximum marginal rate, including highest slab rate of income tax and surcharge applicable to individuals. Section 2(29C) mandates computing maximum marginal rate by considering highest tax rate and surcharge rate for individuals. Surcharge cannot be based on trust's slab rate; it defeats the purpose of discouraging discretionary trusts. Central Processing Centre has power u/s 143(1) to compute correct tax and surcharge amount payable by assessee. Assessee's appeal dismissed, upholding CIT(A)'s order that maximum marginal rate is correctly computed using highest individual tax and surcharge rates.
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