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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HC held that the assessee is entitled to interest u/s 244A on the refund arising from advance tax paid, as the delay in grant of refund was not attributable to the assessee within the meaning of s.244A(2). The assessee had furnished original advance tax challans after filing the return, but the advance tax credit was ultimately allowed and refund granted, with no recorded finding by the AO or appellate authority that any part of the delay in the refund proceedings was attributable to the assessee. Relying on an earlier decision on identical facts, the HC directed that interest u/s 244A be granted on the refund without exclusion of any period on account of alleged delay by the assessee.
HC held that the assessee is entitled to interest u/s 244A on the refund arising from advance tax paid, as the delay in grant of refund was not attributable to the assessee within the meaning of s.244A(2). The assessee had furnished original advance tax challans after filing the return, but the advance tax credit was ultimately allowed and refund granted, with no recorded finding by the AO or appellate authority that any part of the delay in the refund proceedings was attributable to the assessee. Relying on an earlier decision on identical facts, the HC directed that interest u/s 244A be granted on the refund without exclusion of any period on account of alleged delay by the assessee.
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