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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The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had uploaded Form No. 3CFA before the completion of proceedings u/s 143(1) of the Income Tax Act. The ITAT set aside the order of the Additional/Joint Commissioner of Income Tax (Appeals), Panchkula, which had rejected the assessee's appeal and directed the Assessing Officer to tax the royalty income at the normal rate. The ITAT directed the Assessing Officer to tax the royalty income at the special rate of 10% against the normal rate adopted by the Centralized Processing Center (CPC). The grounds raised by the assessee were allowed.
The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had uploaded Form No. 3CFA before the completion of proceedings u/s 143(1) of the Income Tax Act. The ITAT set aside the order of the Additional/Joint Commissioner of Income Tax (Appeals), Panchkula, which had rejected the assessee's appeal and directed the Assessing Officer to tax the royalty income at the normal rate. The ITAT directed the Assessing Officer to tax the royalty income at the special rate of 10% against the normal rate adopted by the Centralized Processing Center (CPC). The grounds raised by the assessee were allowed.
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