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 HC upheld the ITAT's decision deleting the addition under section 40(a)(ia) for short deduction of TDS under sections 194C and 194J. The court affirmed that section 40(a)(ia) is inapplicable to cases of short deduction, thereby negating the revenue's claim for disallowance. The ruling relied on precedent favoring the assessee where conflicting views exist among non-jurisdictional High Courts on the issue. Consequently, the HC found no error in the ITAT's order and dismissed the revenue's appeal, confirming that short deduction of TDS does not warrant disallowance under section 40(a)(ia).
The HC upheld the ITAT's decision deleting the addition under section 40(a)(ia) for short deduction of TDS under sections 194C and 194J. The court affirmed that section 40(a)(ia) is inapplicable to cases of short deduction, thereby negating the revenue's claim for disallowance. The ruling relied on precedent favoring the assessee where conflicting views exist among non-jurisdictional High Courts on the issue. Consequently, the HC found no error in the ITAT's order and dismissed the revenue's appeal, confirming that short deduction of TDS does not warrant disallowance under section 40(a)(ia).
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