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 adjudicated a tax dispute involving TDS liability under Section 194C. The tribunal examined two key issues: (1) food supply bills and (2) business promotion expenses. For food supply transactions, the tribunal determined that GST-subjected food packet supplies do not constitute a service contract, thus Section 194C does not apply. Regarding business promotion expenses, the tribunal referenced a precedent from Ratnagiri Impex Private Limited, which clarified that certain customer facilities do not constitute 'work' under Section 194C. Consequently, the tribunal allowed the assessee's grounds, quashing disallowance of expenses and holding that TDS provisions were not applicable to the specific transactions in question.
ITAT adjudicated a tax dispute involving TDS liability under Section 194C. The tribunal examined two key issues: (1) food supply bills and (2) business promotion expenses. For food supply transactions, the tribunal determined that GST-subjected food packet supplies do not constitute a service contract, thus Section 194C does not apply. Regarding business promotion expenses, the tribunal referenced a precedent from Ratnagiri Impex Private Limited, which clarified that certain customer facilities do not constitute 'work' under Section 194C. Consequently, the tribunal allowed the assessee's grounds, quashing disallowance of expenses and holding that TDS provisions were not applicable to the specific transactions in question.
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