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 allowed the assessee's appeal regarding TDS credit denial. The AO erroneously granted proportionate TDS credit despite the assessee offering total income for the assessment year. The turnover discrepancy between Form 26AS and books was explained through sales returns. When considering sales returns, the declared turnover matched Form 26AS turnover with TDS credit under section 194O. CIT(A) rejected the assessee's explanation based on assumptions that sales returns required replacement goods or gross refunds including TDS. ITAT held that e-platform operators deducted TDS at sale time while returning net amounts to buyers post-TDS deduction. CIT(A)'s rejection was based on presumptions rather than factual analysis, warranting reversal of the lower authorities' decisions.
ITAT allowed the assessee's appeal regarding TDS credit denial. The AO erroneously granted proportionate TDS credit despite the assessee offering total income for the assessment year. The turnover discrepancy between Form 26AS and books was explained through sales returns. When considering sales returns, the declared turnover matched Form 26AS turnover with TDS credit under section 194O. CIT(A) rejected the assessee's explanation based on assumptions that sales returns required replacement goods or gross refunds including TDS. ITAT held that e-platform operators deducted TDS at sale time while returning net amounts to buyers post-TDS deduction. CIT(A)'s rejection was based on presumptions rather than factual analysis, warranting reversal of the lower authorities' decisions.
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