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 Direct Tax Vivad se Vishwas Scheme, 2024 (DTVSV Scheme) provides for resolution of pending income tax litigation. Key clarifications are: Appeals pending as on 22.07.2024, even if subsequently disposed, are eligible. Cases with prosecution instituted before declaration filing are ineligible. Set-aside appeals to ITAT/CIT(A)/DRP are eligible. Credit for taxes paid against disputed demands is available. For deductees availing the scheme, deductors are relieved from liability except interest and can claim expense deduction. The scheme applies to the full dispute, not partial issues. The designated authority can rectify patent errors. Foreign entities can file through representative assessees. Secondary adjustment u/s 92CE applies for transfer pricing cases after settling primary adjustments.
The Direct Tax Vivad se Vishwas Scheme, 2024 (DTVSV Scheme) provides for resolution of pending income tax litigation. Key clarifications are: Appeals pending as on 22.07.2024, even if subsequently disposed, are eligible. Cases with prosecution instituted before declaration filing are ineligible. Set-aside appeals to ITAT/CIT(A)/DRP are eligible. Credit for taxes paid against disputed demands is available. For deductees availing the scheme, deductors are relieved from liability except interest and can claim expense deduction. The scheme applies to the full dispute, not partial issues. The designated authority can rectify patent errors. Foreign entities can file through representative assessees. Secondary adjustment u/s 92CE applies for transfer pricing cases after settling primary adjustments.
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