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 of the assessee and directed the AO to grant credit for TDS, including amounts deducted on maturity of RBI bonds, after verifying claims under Rule 37BA(3)(ii) of the I.T. Rules, 1962. The tribunal noted the assessee had already offered interest on an accrual basis and paid corresponding tax for AYs 2018-19 to 2022-23, having claimed proportionate TDS credits from intermediary deductors. The AO is instructed to verify the TDS receipts, adjust the assessee's computation for AY 2023-24, determine the resultant tax liability or refund, and pass consequential orders in accordance with the tribunal's directions.
The ITAT allowed the appeal of the assessee and directed the AO to grant credit for TDS, including amounts deducted on maturity of RBI bonds, after verifying claims under Rule 37BA(3)(ii) of the I.T. Rules, 1962. The tribunal noted the assessee had already offered interest on an accrual basis and paid corresponding tax for AYs 2018-19 to 2022-23, having claimed proportionate TDS credits from intermediary deductors. The AO is instructed to verify the TDS receipts, adjust the assessee's computation for AY 2023-24, determine the resultant tax liability or refund, and pass consequential orders in accordance with the tribunal's directions.
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