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 HC affirmed the Single Judge's dismissal of the writ petition, holding the appellant's claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant's certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge's view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.
The HC affirmed the Single Judge's dismissal of the writ petition, holding the appellant's claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant's certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge's view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.
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