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 must be allowed in the assessment year in which the related income is assessable, even if the deductor deposited tax and reflected it in Form 26AS in a later year. Following its earlier ruling, ITAT held that the assessee could not be denied credit for AY 2020-21 merely because of a timing mismatch in the deductor's reporting. The Assessing Officer was directed to grant the credit for that year, subject to verification that the same TDS credit is not claimed again in AY 2021-22.
TDS credit must be allowed in the assessment year in which the related income is assessable, even if the deductor deposited tax and reflected it in Form 26AS in a later year. Following its earlier ruling, ITAT held that the assessee could not be denied credit for AY 2020-21 merely because of a timing mismatch in the deductor's reporting. The Assessing Officer was directed to grant the credit for that year, subject to verification that the same TDS credit is not claimed again in AY 2021-22.
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