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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Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
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