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 in part, holding that interest under s.234B cannot be levied beyond the date on which the tax liability was discharged (30.04.2023); accordingly, excess interest computed by the CPC up to the date of processing of the return was directed to be deleted. The Tribunal affirmed the CIT(A)'s conclusion that a particular payment had been correctly characterized by the CPC as a payment under s.140B(1) of the Act, finding no infirmity in that determination; that aspect of the assessment was therefore upheld against the assessee and in favor of the Revenue.
The ITAT allowed the assessee's appeal in part, holding that interest under s.234B cannot be levied beyond the date on which the tax liability was discharged (30.04.2023); accordingly, excess interest computed by the CPC up to the date of processing of the return was directed to be deleted. The Tribunal affirmed the CIT(A)'s conclusion that a particular payment had been correctly characterized by the CPC as a payment under s.140B(1) of the Act, finding no infirmity in that determination; that aspect of the assessment was therefore upheld against the assessee and in favor of the Revenue.
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