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 dominant issue was whether TDS credit could be restricted while processing the return under section 143(1) despite the TDS appearing in Form 26AS. The appellate authority held that credit under section 199 read with Rule 37BA must be granted in accordance with verified TDS and its linkage to income corresponding to the gross receipts, and therefore directed the AO to verify these conditions and allow full TDS credit as reflected in Form 26AS upon such verification. Consequently, the Revenue's challenge was rejected and the appeal was dismissed. - ITAT
The dominant issue was whether TDS credit could be restricted while processing the return under section 143(1) despite the TDS appearing in Form 26AS. The appellate authority held that credit under section 199 read with Rule 37BA must be granted in accordance with verified TDS and its linkage to income corresponding to the gross receipts, and therefore directed the AO to verify these conditions and allow full TDS credit as reflected in Form 26AS upon such verification. Consequently, the Revenue's challenge was rejected and the appeal was dismissed. - ITAT
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