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 ITAT held that credit for TDS originally deducted in the name of the deceased husband shall be allowed to the assessee pursuant to Rule 37BA(2) and (3)(i), as the income is assessable in her hands and reflected in her return. The AO was directed to grant TDS credit accordingly, subject to the assessee obtaining correction of records from the deductor under Rule 37BA, ensuring the TDS is linked to her PAN. The assessee must submit evidence to the AO confirming no other person has claimed this TDS credit. The appeal was allowed for statistical purposes, affirming the assessee's entitlement to TDS credit on income shown by her, despite initial deduction in her deceased husband's name.
The ITAT held that credit for TDS originally deducted in the name of the deceased husband shall be allowed to the assessee pursuant to Rule 37BA(2) and (3)(i), as the income is assessable in her hands and reflected in her return. The AO was directed to grant TDS credit accordingly, subject to the assessee obtaining correction of records from the deductor under Rule 37BA, ensuring the TDS is linked to her PAN. The assessee must submit evidence to the AO confirming no other person has claimed this TDS credit. The appeal was allowed for statistical purposes, affirming the assessee's entitlement to TDS credit on income shown by her, despite initial deduction in her deceased husband's name.
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