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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Cooperative bank appealed against TDS obligations on interest payments to cooperative societies and a temple trust. ITAT held that under Sec 194A(3)(v), cooperative banks are exempt from TDS deduction on interest payments to other cooperative societies, regardless of membership status. The exemption applies broadly to inter-cooperative society transactions. For interest paid to Jagan Nath Temple, ITAT ruled no TDS requirement exists under Sec 194A(3)(iii)(f) as the temple qualifies as a government-financed entity per notification 3489 dated 22/10/1970. The tribunal emphasized that the statutory exemption is explicit and unambiguous, requiring no additional conditions. Appeal allowed, affirming appellant's position on non-deduction of TDS.
Cooperative bank appealed against TDS obligations on interest payments to cooperative societies and a temple trust. ITAT held that under Sec 194A(3)(v), cooperative banks are exempt from TDS deduction on interest payments to other cooperative societies, regardless of membership status. The exemption applies broadly to inter-cooperative society transactions. For interest paid to Jagan Nath Temple, ITAT ruled no TDS requirement exists under Sec 194A(3)(iii)(f) as the temple qualifies as a government-financed entity per notification 3489 dated 22/10/1970. The tribunal emphasized that the statutory exemption is explicit and unambiguous, requiring no additional conditions. Appeal allowed, affirming appellant's position on non-deduction of TDS.
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