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, in execution of an arbitral award and additional award, held that no TDS is deductible at source from sums payable under a decree or arbitral award absent express statutory authorization. The Award Debtor's deduction of TDS while releasing the decretal amount was found erroneous, and HC directed refund of the deducted sums to the Award Holder. However, HC rejected the Award Holder's claim for interest on the TDS component, terming the deduction a bona fide procedural error and holding that imposing interest would be inequitable. Award Debtor may seek recovery/refund from tax authorities. Execution petition was disposed of.
HC, in execution of an arbitral award and additional award, held that no TDS is deductible at source from sums payable under a decree or arbitral award absent express statutory authorization. The Award Debtor's deduction of TDS while releasing the decretal amount was found erroneous, and HC directed refund of the deducted sums to the Award Holder. However, HC rejected the Award Holder's claim for interest on the TDS component, terming the deduction a bona fide procedural error and holding that imposing interest would be inequitable. Award Debtor may seek recovery/refund from tax authorities. Execution petition was disposed of.
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