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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Tax deducted at source (TDS) issue related to agency services payments. Assessee demonstrated Form No. 3CD and Annexure D, showing TDS deducted u/s 194C on payments to partner firm. Commissioner of Income Tax (Appeals) [CIT(A)] examined facts, provisions, assessee's submissions, and Clause 23 of Tax Audit Report regarding payments u/s 40A(2)(b). CIT(A) passed reasoned order after considering factual information. Income Tax Appellate Tribunal (ITAT) upheld CIT(A)'s order, finding no infirmity, and dismissed revenue's appeal grounds.
Tax deducted at source (TDS) issue related to agency services payments. Assessee demonstrated Form No. 3CD and Annexure D, showing TDS deducted u/s 194C on payments to partner firm. Commissioner of Income Tax (Appeals) [CIT(A)] examined facts, provisions, assessee's submissions, and Clause 23 of Tax Audit Report regarding payments u/s 40A(2)(b). CIT(A) passed reasoned order after considering factual information. Income Tax Appellate Tribunal (ITAT) upheld CIT(A)'s order, finding no infirmity, and dismissed revenue's appeal grounds.
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