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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Credit of TDS under s. 199 was denied on the ground that the corresponding income was offered to tax by a related entity rather than by the assessee in the year of claim. It was held that where TDS has been deducted and deposited, and the credit appears in the assessee's Form 26AS, the assessee is entitled to such credit, consistent with settled precedent; however, safeguards are required to prevent double credit. The Assessing Officer was directed to grant the TDS credit after verifying that the related entity has not claimed the same TDS credit in its own assessment. Appeal allowed. - ITAT
Credit of TDS under s. 199 was denied on the ground that the corresponding income was offered to tax by a related entity rather than by the assessee in the year of claim. It was held that where TDS has been deducted and deposited, and the credit appears in the assessee's Form 26AS, the assessee is entitled to such credit, consistent with settled precedent; however, safeguards are required to prevent double credit. The Assessing Officer was directed to grant the TDS credit after verifying that the related entity has not claimed the same TDS credit in its own assessment. Appeal allowed. - ITAT
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