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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TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
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