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 rejected the assessee's claim for deducting interest on delayed deposit of employee provident fund contributions. The tribunal held that interest on late PF deposits cannot be claimed as a business expenditure under Section 37(1). The non-obstante clause of Section 43B mandates timely payment of statutory liabilities, and employee contributions are trust monies that must be deposited within specified due dates. Explanation 1 to Section 37 prohibits deductions for legally prohibited actions. The tribunal upheld the CPC's disallowance, emphasizing the legislative intent to protect workers' social security by ensuring timely remittance of statutory dues. Appeal was decided against the assessee.
ITAT rejected the assessee's claim for deducting interest on delayed deposit of employee provident fund contributions. The tribunal held that interest on late PF deposits cannot be claimed as a business expenditure under Section 37(1). The non-obstante clause of Section 43B mandates timely payment of statutory liabilities, and employee contributions are trust monies that must be deposited within specified due dates. Explanation 1 to Section 37 prohibits deductions for legally prohibited actions. The tribunal upheld the CPC's disallowance, emphasizing the legislative intent to protect workers' social security by ensuring timely remittance of statutory dues. Appeal was decided against the assessee.
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