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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Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
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