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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT allowed the revision challenge and set aside the exercise of power under section 263, holding that the AO's original treatment of the payments as taxable under section 194I was not erroneous when made, the issue being debatable and pending adjudication before the first appellate authority. The PCIT's subsequent cancellation of the assessment by invoking section 194C (with a lower withholding rate) was sustained as correctly treating EDC payments to the statutory authority as contract payments, but the PCIT erred in initiating revision while the matter remained before the CIT(A). There was no material prejudice to Revenue; matter ultimately decided in favour of the assessee.
The ITAT allowed the revision challenge and set aside the exercise of power under section 263, holding that the AO's original treatment of the payments as taxable under section 194I was not erroneous when made, the issue being debatable and pending adjudication before the first appellate authority. The PCIT's subsequent cancellation of the assessment by invoking section 194C (with a lower withholding rate) was sustained as correctly treating EDC payments to the statutory authority as contract payments, but the PCIT erred in initiating revision while the matter remained before the CIT(A). There was no material prejudice to Revenue; matter ultimately decided in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
