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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Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
Admission of additional evidence under Rule 29 of ITAT Rules was allowed and admitted. Non-deduction of tax at source was considered: for two payees, production and departmental verification of TDS certificates established that the assessee is not in default, and the demand under section 201(1) and interest under section 201(1A) relating to those payments were deleted. For two other payees, a 30% disallowance of expenditure for non-deduction was upheld and the Assessing Officer was directed to recompute any liability accordingly. Verification of TDS return filing was ordered and fee under section 234E to be deleted if return was timely.
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