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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National Pension Scheme (NPS) contributions made by an employer were disallowed by the Assessing Officer on the grounds that the remittances were made beyond the prescribed date under the Pension Fund Regulatory and Development Authority Act, 2013. The ITAT, relying on the case of Adani Petronet (Dahej) Port (P.) Ltd., observed that there was no due date prescribed in the PFRDA Act for making payments to the NPS account. Further, all payments were made before filing the return of income u/s 139(1). The ITAT held that the adjustment made on NPS payments was unjustified, and the amount should be treated as allowable u/s 43B(b). Additionally, a notification issued by the Department of Pension and Pensioners' Welfare clarified that the National Pension System Rules, 2021 apply only to government servants and not the general public. Consequently, the assessee's appeal was allowed.
National Pension Scheme (NPS) contributions made by an employer were disallowed by the Assessing Officer on the grounds that the remittances were made beyond the prescribed date under the Pension Fund Regulatory and Development Authority Act, 2013. The ITAT, relying on the case of Adani Petronet (Dahej) Port (P.) Ltd., observed that there was no due date prescribed in the PFRDA Act for making payments to the NPS account. Further, all payments were made before filing the return of income u/s 139(1). The ITAT held that the adjustment made on NPS payments was unjustified, and the amount should be treated as allowable u/s 43B(b). Additionally, a notification issued by the Department of Pension and Pensioners' Welfare clarified that the National Pension System Rules, 2021 apply only to government servants and not the general public. Consequently, the assessee's appeal was allowed.
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