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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The CBDT issued Circular No. 8/2025 clarifying the application of its earlier Circular No. 5/2025 regarding waiver of interest under sections 201(1A)(ii) and 206C(7) of the Income-tax Act, 1961. The clarification establishes that prescribed authorities (CCIT/DGIT/Pr. CCIT) are empowered to pass waiver orders only after the circular's issuance date. However, waiver applications may be entertained for interest charged even before the circular's issuance, provided applications are filed within one year from the end of the relevant financial year. The circular addresses field authorities' representations seeking temporal scope clarification for waiver eligibility and procedural implementation.
The CBDT issued Circular No. 8/2025 clarifying the application of its earlier Circular No. 5/2025 regarding waiver of interest under sections 201(1A)(ii) and 206C(7) of the Income-tax Act, 1961. The clarification establishes that prescribed authorities (CCIT/DGIT/Pr. CCIT) are empowered to pass waiver orders only after the circular's issuance date. However, waiver applications may be entertained for interest charged even before the circular's issuance, provided applications are filed within one year from the end of the relevant financial year. The circular addresses field authorities' representations seeking temporal scope clarification for waiver eligibility and procedural implementation.
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