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 allowed the assessee's appeal and directed the revenue to grant full credit for TDS withheld on part payment, holding that the entire sale consideration was declared and taxed in AY 2019-20 and income cannot be taxed twice. On verification of Form 26AS for AY 2019-20 and AY 2023-24 the sale consideration matched the assessee's declaration; hence TDS deducted on subsequent part settlement must be credited. The Tribunal set aside CIT(A)'s rejection of the assessee's claim as erroneous, restored the assessee's TDS claim (including the TDS reflected for AY 2023-24) and remitted to the assessing authority/CPC to give appropriate credit under the Act.
ITAT allowed the assessee's appeal and directed the revenue to grant full credit for TDS withheld on part payment, holding that the entire sale consideration was declared and taxed in AY 2019-20 and income cannot be taxed twice. On verification of Form 26AS for AY 2019-20 and AY 2023-24 the sale consideration matched the assessee's declaration; hence TDS deducted on subsequent part settlement must be credited. The Tribunal set aside CIT(A)'s rejection of the assessee's claim as erroneous, restored the assessee's TDS claim (including the TDS reflected for AY 2023-24) and remitted to the assessing authority/CPC to give appropriate credit under the Act.
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