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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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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