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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HC allowed NRI assessee's petition regarding TDS credit, directing revenue authorities to correct the record and reflect TDS deposit in Form 26QB retroactively from original deposit date. The court mandated revenue to compute potential refund in accordance with law, effectively resolving the procedural error stemming from incorrect form submission. The ruling emphasized rectifying administrative mistakes without requiring additional buyer consent, thereby facilitating the NRI's tax credit claim and eliminating bureaucratic impediments to proper tax documentation.
HC allowed NRI assessee's petition regarding TDS credit, directing revenue authorities to correct the record and reflect TDS deposit in Form 26QB retroactively from original deposit date. The court mandated revenue to compute potential refund in accordance with law, effectively resolving the procedural error stemming from incorrect form submission. The ruling emphasized rectifying administrative mistakes without requiring additional buyer consent, thereby facilitating the NRI's tax credit claim and eliminating bureaucratic impediments to proper tax documentation.
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