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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Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
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