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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The text addresses applications under section 197 for determination of withholding tax rate, emphasising that the competent authority must consider the nature of transactions and relevant material before fixing a NIL or other rate; the court declined to direct issuance of a NIL certificate because no authority had examined transaction nature. The court quashed the earlier administrative order and certificate and directed reissuance of a certificate at a lower rate so the assessee must file returns and may be subjected to scrutiny under CBDT criteria; it also ordered time limits for issuing the certificate and for future applications to be decided within the prescribed period.
The text addresses applications under section 197 for determination of withholding tax rate, emphasising that the competent authority must consider the nature of transactions and relevant material before fixing a NIL or other rate; the court declined to direct issuance of a NIL certificate because no authority had examined transaction nature. The court quashed the earlier administrative order and certificate and directed reissuance of a certificate at a lower rate so the assessee must file returns and may be subjected to scrutiny under CBDT criteria; it also ordered time limits for issuing the certificate and for future applications to be decided within the prescribed period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
