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 held that TDS provisions under s.194C apply to transport payments made by assessee to transporters, despite no direct contract between parties. While payments below Rs.50,000 are exempt from TDS per s.194C(5), assessee's claim of Rs.1,00,524 for such payments was allowed. On the broader disallowance under s.40(a)(ia), matter remanded to AO to examine application of amended first proviso limiting disallowance to 30% of expenditure, effective retrospectively from April 1, 2015. Though assessee hadn't previously raised this amendment argument, ITAT permitted fresh consideration by AO for statistical purposes. Ground regarding sub-threshold payments allowed; alternative ground on limited disallowance remanded.
ITAT held that TDS provisions under s.194C apply to transport payments made by assessee to transporters, despite no direct contract between parties. While payments below Rs.50,000 are exempt from TDS per s.194C(5), assessee's claim of Rs.1,00,524 for such payments was allowed. On the broader disallowance under s.40(a)(ia), matter remanded to AO to examine application of amended first proviso limiting disallowance to 30% of expenditure, effective retrospectively from April 1, 2015. Though assessee hadn't previously raised this amendment argument, ITAT permitted fresh consideration by AO for statistical purposes. Ground regarding sub-threshold payments allowed; alternative ground on limited disallowance remanded.
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