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...
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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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT ruled that alternative accommodation charges paid to tenants under SRA scheme do not constitute consideration for share in land/building under development agreement. Following precedent in Nathani Parekh Construction case, tribunal held such payments categorized as 'Rent to Tenant SRA' fall outside scope of TDS provisions under section 194-IC. CIT(A)'s order deleting tax and interest levied under sections 201(1) and 201(1A) upheld. The ruling clarifies that temporary accommodation expenses during redevelopment are distinct from property share compensation, exempting them from TDS requirements. Appeal resolved in taxpayer's favor.
ITAT ruled that alternative accommodation charges paid to tenants under SRA scheme do not constitute consideration for share in land/building under development agreement. Following precedent in Nathani Parekh Construction case, tribunal held such payments categorized as 'Rent to Tenant SRA' fall outside scope of TDS provisions under section 194-IC. CIT(A)'s order deleting tax and interest levied under sections 201(1) and 201(1A) upheld. The ruling clarifies that temporary accommodation expenses during redevelopment are distinct from property share compensation, exempting them from TDS requirements. Appeal resolved in taxpayer's favor.
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