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 allowed the assessee's appeal, directing the AO to grant credit for TDS purportedly deducted by the employer notwithstanding non-deposit by the employer due to bank-related constraints. The Tribunal held that the assessee is entitled to carry forward and receive benefit of the tax credit reflected as deducted by the employer for the relevant assessment years, and, where the Revenue had recovered or adjusted amounts in the interim, the assessee shall be entitled to refund. The Revenue is permitted to pursue statutory remedies against the employer for non-deposit of TDS in accordance with law. The appeal is disposed of in favour of the assessee.
The ITAT allowed the assessee's appeal, directing the AO to grant credit for TDS purportedly deducted by the employer notwithstanding non-deposit by the employer due to bank-related constraints. The Tribunal held that the assessee is entitled to carry forward and receive benefit of the tax credit reflected as deducted by the employer for the relevant assessment years, and, where the Revenue had recovered or adjusted amounts in the interim, the assessee shall be entitled to refund. The Revenue is permitted to pursue statutory remedies against the employer for non-deposit of TDS in accordance with law. The appeal is disposed of in favour of the assessee.
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