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 credit claims not reflected in Form 26AS require AO verification before allowance; the appellate direction permitting credit where Form 26AS shows TDS, or where the assessee produces evidence plus an indemnity bond, is valid only if the AO conducts necessary verification. The Tribunal found CIT(A) did not mandate unconditional credit but correctly required verification and therefore dismissed Revenue's challenge and the assessee's cross-objection, upholding that credits may be allowed after the AO's appropriate verification.
TDS credit claims not reflected in Form 26AS require AO verification before allowance; the appellate direction permitting credit where Form 26AS shows TDS, or where the assessee produces evidence plus an indemnity bond, is valid only if the AO conducts necessary verification. The Tribunal found CIT(A) did not mandate unconditional credit but correctly required verification and therefore dismissed Revenue's challenge and the assessee's cross-objection, upholding that credits may be allowed after the AO's appropriate verification.
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