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 regarding disallowance of employees' provident fund contributions deposited after statutory due dates. Despite being processed under section 143(1) prior to the Supreme Court's Checkmate judgment, the tribunal upheld disallowance of such contributions. Following precedents from BPS Infrastructure and Allied Motors, the tribunal determined that late contributions remain non-deductible. The assessee's challenge to the disallowance was rejected, with the tribunal affirming the CIT(A)'s reasoning that late statutory payments cannot be considered eligible for tax deduction. Consequently, the assessee's appeal was dismissed, maintaining the original disallowance of provident fund contribution expenses.
ITAT adjudicated a tax dispute regarding disallowance of employees' provident fund contributions deposited after statutory due dates. Despite being processed under section 143(1) prior to the Supreme Court's Checkmate judgment, the tribunal upheld disallowance of such contributions. Following precedents from BPS Infrastructure and Allied Motors, the tribunal determined that late contributions remain non-deductible. The assessee's challenge to the disallowance was rejected, with the tribunal affirming the CIT(A)'s reasoning that late statutory payments cannot be considered eligible for tax deduction. Consequently, the assessee's appeal was dismissed, maintaining the original disallowance of provident fund contribution expenses.
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