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 condoned the effective delay of 834 days in filing the appeals by the assessee, holding that sufficient cause existed within the meaning of S.5 of the Limitation Act, particularly in light of the exclusion of the period from 15.03.2020 to 28.02.2022 for limitation purposes as directed by the Apex Court. On merits, ITAT noted that the TDS demand raised u/s 200A(1) resulted from data entry errors in e-filing of TDS returns through NSDL, leading to TDS mismatch. Observing that the assessee's claim appeared genuine, ITAT set aside the impugned orders and remanded all five matters to the AO with directions to grant access to the CONSOLE file in the TDS module, allow reconciliation, and rectify mismatches in accordance with law.
ITAT condoned the effective delay of 834 days in filing the appeals by the assessee, holding that sufficient cause existed within the meaning of S.5 of the Limitation Act, particularly in light of the exclusion of the period from 15.03.2020 to 28.02.2022 for limitation purposes as directed by the Apex Court. On merits, ITAT noted that the TDS demand raised u/s 200A(1) resulted from data entry errors in e-filing of TDS returns through NSDL, leading to TDS mismatch. Observing that the assessee's claim appeared genuine, ITAT set aside the impugned orders and remanded all five matters to the AO with directions to grant access to the CONSOLE file in the TDS module, allow reconciliation, and rectify mismatches in accordance with law.
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