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 directed the Assessing Officer to grant the appellant credit for TDS under s.199 in respect of income accepted as the appellant's for AY 2021-22, after verifying the assessment records of the appellant's father to ensure he has not claimed the corresponding TDS; the appellant must furnish relevant documents and will be afforded a reasonable opportunity of hearing. The Tribunal noted no dispute on the character or taxable ownership of the income, no allegation of mala fides, and that a similarly situated sibling's claim had been allowed. The CIT(A)'s order is set aside and the grounds advanced by the appellant are allowed for statistical purposes.
ITAT directed the Assessing Officer to grant the appellant credit for TDS under s.199 in respect of income accepted as the appellant's for AY 2021-22, after verifying the assessment records of the appellant's father to ensure he has not claimed the corresponding TDS; the appellant must furnish relevant documents and will be afforded a reasonable opportunity of hearing. The Tribunal noted no dispute on the character or taxable ownership of the income, no allegation of mala fides, and that a similarly situated sibling's claim had been allowed. The CIT(A)'s order is set aside and the grounds advanced by the appellant are allowed for statistical purposes.
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