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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Dispute concerns entitlement to TDS credit where the assessee acted as a Kaccha Arhtia (commission agent). Tribunal accepted that amounts received by traders on behalf of farmers were not the assessees revenue, while commission receipts constituted the assessees income; TDS deducted from payments that were the assessees money must be allowed as credit. The tribunal directed the assessing officer to grant full TDS credit to the assessee, noting the nature of receipts rather than specific provisions under which TDS was deducted.
Dispute concerns entitlement to TDS credit where the assessee acted as a Kaccha Arhtia (commission agent). Tribunal accepted that amounts received by traders on behalf of farmers were not the assessees revenue, while commission receipts constituted the assessees income; TDS deducted from payments that were the assessees money must be allowed as credit. The tribunal directed the assessing officer to grant full TDS credit to the assessee, noting the nature of receipts rather than specific provisions under which TDS was deducted.
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