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 held that the amount of TDS (Tax Deducted at Source) reflected in Form 26AS of the assessee for the year under consideration, in respect of TDS done by PBA Infrastructure Pvt. Ltd., is to be treated as an item of income under the head "income from other sources." The provisions of section 198 of the Income Tax Act are to be applied accordingly. Once TDS is deducted, the assessee cannot be permitted to use the certificate to cover other amounts while refusing to show the amount of interest in their return by resorting to a difference in the method of accounting system. The Assessing Officer was directed to recompute the assessed total income in terms of the Tribunal's observations and findings.
The Income Tax Appellate Tribunal held that the amount of TDS (Tax Deducted at Source) reflected in Form 26AS of the assessee for the year under consideration, in respect of TDS done by PBA Infrastructure Pvt. Ltd., is to be treated as an item of income under the head "income from other sources." The provisions of section 198 of the Income Tax Act are to be applied accordingly. Once TDS is deducted, the assessee cannot be permitted to use the certificate to cover other amounts while refusing to show the amount of interest in their return by resorting to a difference in the method of accounting system. The Assessing Officer was directed to recompute the assessed total income in terms of the Tribunal's observations and findings.
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