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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HC dismissed petition seeking permission to file revised return beyond limitation period. Petitioner claimed additional TDS credit of Rs. 1,83,770 (difference between Rs. 2,69,338 and Rs. 85,568) for AY 2012-13 due to subsequent crediting of TDS on works contract by Government employer. Court held that delay condonation under CBDT Circular not applicable as limitation period u/s 148 read with Section 151 of Income Tax Act had expired. TDS credited in subsequent year can only be utilized for succeeding assessment year. Attempt to enhance taxable income through revised return for additional refund was rejected as time-barred.
HC dismissed petition seeking permission to file revised return beyond limitation period. Petitioner claimed additional TDS credit of Rs. 1,83,770 (difference between Rs. 2,69,338 and Rs. 85,568) for AY 2012-13 due to subsequent crediting of TDS on works contract by Government employer. Court held that delay condonation under CBDT Circular not applicable as limitation period u/s 148 read with Section 151 of Income Tax Act had expired. TDS credited in subsequent year can only be utilized for succeeding assessment year. Attempt to enhance taxable income through revised return for additional refund was rejected as time-barred.
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