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 could not be denied where income received after the taxpayer's husband's death was accepted and assessed in the legal heir's hands, even though the deduction was reflected against the deceased's PAN. The Tribunal held that once the assessee was recognised on the tax portal as the legal heir and the deceased's PAN had been surrendered, the Revenue could not tax the same income in her hands and simultaneously refuse credit for tax deducted from it. The objection that the return was not filed in the capacity of legal heir was rejected, and TDS credit with consequential refund and interest was directed.
TDS credit could not be denied where income received after the taxpayer's husband's death was accepted and assessed in the legal heir's hands, even though the deduction was reflected against the deceased's PAN. The Tribunal held that once the assessee was recognised on the tax portal as the legal heir and the deceased's PAN had been surrendered, the Revenue could not tax the same income in her hands and simultaneously refuse credit for tax deducted from it. The objection that the return was not filed in the capacity of legal heir was rejected, and TDS credit with consequential refund and interest was directed.
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