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 multiple tax issues involving TDS, section 14A, and CSR expenses. On TDS u/s 195, the tribunal held that commission paid to non-resident for services rendered outside India is not chargeable to tax, thus TDS deduction was not mandatory. Regarding section 14A, the tribunal found no exempt income was generated, rendering disallowance impermissible. For CSR expenses, the tribunal upheld the disallowance under section 37(1) as the assessee failed to substantiate that expenses were incurred exclusively for business purposes. The tribunal deleted TDS and section 14A additions while maintaining CSR expense disallowance.
ITAT adjudicated multiple tax issues involving TDS, section 14A, and CSR expenses. On TDS u/s 195, the tribunal held that commission paid to non-resident for services rendered outside India is not chargeable to tax, thus TDS deduction was not mandatory. Regarding section 14A, the tribunal found no exempt income was generated, rendering disallowance impermissible. For CSR expenses, the tribunal upheld the disallowance under section 37(1) as the assessee failed to substantiate that expenses were incurred exclusively for business purposes. The tribunal deleted TDS and section 14A additions while maintaining CSR expense disallowance.
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