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 case pertains to the levy of interest u/s 234C for failure on the part of the payer to deduct tax deducted at source (TDS) u/ss 196D and 194LD. The key points are: Tax due on returned income means the tax chargeable on the total income declared in the return, reduced by the TDS amount. The advance tax is reduced by the TDS amount, meaning the assessee is not required to pay advance tax to that extent. Since the payers failed to deduct TDS, the assessee paid the full tax. Therefore, interest u/s 234C cannot be levied on the assessee for the payers' fault. The Bombay High Court in Ngc Network Asia LLC held that when the payer fails to deduct TDS, no interest u/s 234B can be imposed on the payee assessee. It is not a case of deferment in payment of advance tax u/s 234C since the assessee discharged the tax liability. Thus, the Appellate Tribunal directed the Assessing Officer to delete the impugned addition of interest u/s 234C, deciding in favor of the assessee.
The case pertains to the levy of interest u/s 234C for failure on the part of the payer to deduct tax deducted at source (TDS) u/ss 196D and 194LD. The key points are: Tax due on returned income means the tax chargeable on the total income declared in the return, reduced by the TDS amount. The advance tax is reduced by the TDS amount, meaning the assessee is not required to pay advance tax to that extent. Since the payers failed to deduct TDS, the assessee paid the full tax. Therefore, interest u/s 234C cannot be levied on the assessee for the payers' fault. The Bombay High Court in Ngc Network Asia LLC held that when the payer fails to deduct TDS, no interest u/s 234B can be imposed on the payee assessee. It is not a case of deferment in payment of advance tax u/s 234C since the assessee discharged the tax liability. Thus, the Appellate Tribunal directed the Assessing Officer to delete the impugned addition of interest u/s 234C, deciding in favor of the assessee.
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