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 assessee paid consideration over Rs. 50 lakh for purchase of property whose stamp duty valuation exceeded Rs. 50 lakh. Though TDS was deducted voluntarily, it was deposited belatedly along with Form 26QB. CIT(A) rejected assessee's claim of agricultural land exemption u/s 194IA(2). ITAT upheld levy of penalty u/s 234E for late filing of TDS return, as delayed deposit denied TDS credit to deductee, despite voluntary deduction. Assessee's appeal was dismissed.
The assessee paid consideration over Rs. 50 lakh for purchase of property whose stamp duty valuation exceeded Rs. 50 lakh. Though TDS was deducted voluntarily, it was deposited belatedly along with Form 26QB. CIT(A) rejected assessee's claim of agricultural land exemption u/s 194IA(2). ITAT upheld levy of penalty u/s 234E for late filing of TDS return, as delayed deposit denied TDS credit to deductee, despite voluntary deduction. Assessee's appeal was dismissed.
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