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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Tribunal rejected the Assessing Officer's unexamined application of a higher withholding rate where the payer's case was that payees were unidentified, and held that applicability of the higher rate cannot be presumed without record support. The Tribunal remitted the disallowances under payroll withholding provisions for de novo verification of whether tax was in fact deducted and deposited under Chapter XVII-B, allowing the assessee to file supporting details. Separately, the Tribunal set aside denial of deduction for CSR payments and remitted the matter for AO verification of compliance with statutory conditions for charitable deductions under Chapter VIA.
Tribunal rejected the Assessing Officer's unexamined application of a higher withholding rate where the payer's case was that payees were unidentified, and held that applicability of the higher rate cannot be presumed without record support. The Tribunal remitted the disallowances under payroll withholding provisions for de novo verification of whether tax was in fact deducted and deposited under Chapter XVII-B, allowing the assessee to file supporting details. Separately, the Tribunal set aside denial of deduction for CSR payments and remitted the matter for AO verification of compliance with statutory conditions for charitable deductions under Chapter VIA.
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