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 dismissed the appeal regarding tax deduction at source for Leave Travel Concession (LTC) payments to employees. The tribunal found no reasonable cause under section 273B for failing to deduct tax on foreign travel reimbursements. Despite being a leading corporate entity with substantial intellectual resources, the assessee could not substantiate its claim of bonafide belief about tax non-deductibility. The tribunal rejected the assessee's explanation of lack of knowledge as insufficient, confirming the original demand by the Assessing Officer for non-compliance with tax deduction requirements. The appeal was consequently dismissed, upholding the CIT(A)'s appellate order.
ITAT dismissed the appeal regarding tax deduction at source for Leave Travel Concession (LTC) payments to employees. The tribunal found no reasonable cause under section 273B for failing to deduct tax on foreign travel reimbursements. Despite being a leading corporate entity with substantial intellectual resources, the assessee could not substantiate its claim of bonafide belief about tax non-deductibility. The tribunal rejected the assessee's explanation of lack of knowledge as insufficient, confirming the original demand by the Assessing Officer for non-compliance with tax deduction requirements. The appeal was consequently dismissed, upholding the CIT(A)'s appellate order.
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