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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Payment made by bearer cheques to material suppliers in assessee's contract business was challenged under s.40A(3). Gram Panchayat Mukhias' certificates confirmed absence of bank branches in suppliers' villages. ITAT held Rule 6DDJ applicable, validating bearer cheque payments due to banking infrastructure limitations. Regarding s.40(a)(ia) violation for non-deduction of TDS on Rs.2,95,000 paid to Mangla Planners for map design, matter remanded to AO following Hindusthan Coca Cola precedent. AO directed to verify if recipients declared amounts as taxable income and examine whether their income falls below taxable threshold. Disallowance under s.40A(3) reversed; s.40(a)(ia) issue remanded for verification.
Payment made by bearer cheques to material suppliers in assessee's contract business was challenged under s.40A(3). Gram Panchayat Mukhias' certificates confirmed absence of bank branches in suppliers' villages. ITAT held Rule 6DDJ applicable, validating bearer cheque payments due to banking infrastructure limitations. Regarding s.40(a)(ia) violation for non-deduction of TDS on Rs.2,95,000 paid to Mangla Planners for map design, matter remanded to AO following Hindusthan Coca Cola precedent. AO directed to verify if recipients declared amounts as taxable income and examine whether their income falls below taxable threshold. Disallowance under s.40A(3) reversed; s.40(a)(ia) issue remanded for verification.
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