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 interest under section 234B is payable only up to the date of payment of self-assessment tax under section 140A and thereafter only to the extent of any residual shortfall arising from assessment; where the return was processed under section 143(1) without any variation in tax liability, no further shortfall arose. Consequently, CPC erred in computing interest under section 234B beyond the date of self-assessment tax payment (03.04.2023). The excess interest so charged is a mistake apparent on the record and not sustainable; the assessee's appeal is allowed and the impugned interest liability is quashed to the extent charged after the payment date.
ITAT held that interest under section 234B is payable only up to the date of payment of self-assessment tax under section 140A and thereafter only to the extent of any residual shortfall arising from assessment; where the return was processed under section 143(1) without any variation in tax liability, no further shortfall arose. Consequently, CPC erred in computing interest under section 234B beyond the date of self-assessment tax payment (03.04.2023). The excess interest so charged is a mistake apparent on the record and not sustainable; the assessee's appeal is allowed and the impugned interest liability is quashed to the extent charged after the payment date.
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