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 held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
ITAT held that assessee was not liable for TDS default under Section 201(1)/201(1A) regarding immovable property transactions. For property purchased on 30.01.2018, where consideration paid to each of four co-owners was Rs. 40,25,000 (below Rs. 50 lakhs threshold), no TDS deduction was required under Section 194IA. The amended provision requiring aggregate consideration of all transferors applies only from 01.10.2024. Similarly, for property purchased on 30.08.2017 with consideration below Rs. 50 lakhs, stamp duty value consideration was not applicable before 01.04.2022. However, regarding audit fee payment, assessee was correctly treated as in default under Section 194J. Matter remanded to TDS AO for verification of recipient's tax payment and restricting interest computation from deduction date to recipient's return filing date. Demands under Section 201(1)/201(1A) for property transactions deleted.
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