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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
TDS u/s 194C was disallowed for 'Crew Wages Expenses' u/s 40(a)(ia) by the AO, considering the assessee as a sub-contractor required to deduct TDS. The assessee contended being a contractor in a principal-to-principal arrangement for providing crew, not covered under 194C contracts. The ITAT held that for 194C(2) applicability, conditions of the assessee being a contractor, entering into a sub-contract where the sub-contractor carries out part of the contractor's work, and payment for such work, must be satisfied. In this case, the assessee was solely responsible for execution, suggesting no transfer of contractual responsibility to crew as sub-contractors. Absence of such sub-contract rendered 194C and consequently 40(a)(ia) incorrectly invoked. The ITAT allowed the ground, relying on Prashant H. Shah.
TDS u/s 194C was disallowed for 'Crew Wages Expenses' u/s 40(a)(ia) by the AO, considering the assessee as a sub-contractor required to deduct TDS. The assessee contended being a contractor in a principal-to-principal arrangement for providing crew, not covered under 194C contracts. The ITAT held that for 194C(2) applicability, conditions of the assessee being a contractor, entering into a sub-contract where the sub-contractor carries out part of the contractor's work, and payment for such work, must be satisfied. In this case, the assessee was solely responsible for execution, suggesting no transfer of contractual responsibility to crew as sub-contractors. Absence of such sub-contract rendered 194C and consequently 40(a)(ia) incorrectly invoked. The ITAT allowed the ground, relying on Prashant H. Shah.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
