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 tax authority partially modifies a prior circular regarding consequences of PAN cards becoming inoperative under Rule 114AAA of the Income-tax Rules. It clarifies that no liability shall arise for deductors or collectors to apply higher TDS/TCS rates under sections 206AA/206CC when payments made between April 1, 2024, and July 31, 2025, involve PANs made operative by Aadhaar linkage on or before September 30, 2025, or when payments made on or after August 1, 2025, involve PANs made operative within two months from the end of the payment month. This amendment aims to address grievances where demands were raised for short deduction/collection despite PANs becoming operative within specified timelines. Other applicable provisions of the Income-tax Act remain enforceable.
The tax authority partially modifies a prior circular regarding consequences of PAN cards becoming inoperative under Rule 114AAA of the Income-tax Rules. It clarifies that no liability shall arise for deductors or collectors to apply higher TDS/TCS rates under sections 206AA/206CC when payments made between April 1, 2024, and July 31, 2025, involve PANs made operative by Aadhaar linkage on or before September 30, 2025, or when payments made on or after August 1, 2025, involve PANs made operative within two months from the end of the payment month. This amendment aims to address grievances where demands were raised for short deduction/collection despite PANs becoming operative within specified timelines. Other applicable provisions of the Income-tax Act remain enforceable.
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