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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Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
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