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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Salary paid to an accountant at Rs. 12,000 per month is not liable for tax deduction at source u/s 194J as it is a salary expenditure, not payment towards professional or technical services. The total salary amount paid is below the taxable limit, hence no TDS obligation arises u/s 192. Consequently, the disallowance u/s 40(a)(ia) for non-deduction of tax at source u/s 194J is deleted as the payment is towards salary and not professional fees. The Appellate Tribunal set aside the findings of the CIT(A) and allowed the assessee's appeal on this issue.
Salary paid to an accountant at Rs. 12,000 per month is not liable for tax deduction at source u/s 194J as it is a salary expenditure, not payment towards professional or technical services. The total salary amount paid is below the taxable limit, hence no TDS obligation arises u/s 192. Consequently, the disallowance u/s 40(a)(ia) for non-deduction of tax at source u/s 194J is deleted as the payment is towards salary and not professional fees. The Appellate Tribunal set aside the findings of the CIT(A) and allowed the assessee's appeal on this issue.
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