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 appeal and directed the AO to grant credit for TDS deducted though reported under the PAN of an erstwhile partnership, finding the income was offered and assessed in the hands of the assessee company, the partnership has not claimed the credit, and the Revenue has received the tax. Relying on Section 199 read with Rule 37BA, the Tribunal held that denial of credit due to deductor's reporting error would occasion impermissible double taxation and frustrate the statutory purpose of TDS. Grant of credit is subject to verification that the partnership has not claimed the said TDS in its return.
The ITAT allowed the appeal and directed the AO to grant credit for TDS deducted though reported under the PAN of an erstwhile partnership, finding the income was offered and assessed in the hands of the assessee company, the partnership has not claimed the credit, and the Revenue has received the tax. Relying on Section 199 read with Rule 37BA, the Tribunal held that denial of credit due to deductor's reporting error would occasion impermissible double taxation and frustrate the statutory purpose of TDS. Grant of credit is subject to verification that the partnership has not claimed the said TDS in its return.
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