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 upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law.
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