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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ITAT held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
ITAT held that foreign remittances characterized as "management/processing fees" are not taxable as fees for technical services (FTS) and therefore the addition treating them as FTS is deleted; the appeal ground challenging taxability is allowed following a co-ordinate bench precedent in the assessee's own case. With respect to levy of fee under s.234F, the Tribunal directed the AO to verify the assessee's contention that the return was filed in response to an s.148 notice and, if established, to take action in accordance with law regarding applicability of s.234F.
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