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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Compensation awarded under an arbitral award made under Section 3G(5) of the National Highways Act, 1956 was stated to be exempt from TDS in view of Section 96 of the 2013 Land Acquisition Act, which the Court treated as applicable to post-enactment compensation, including acquisitions under the National Highways Act. It further noted that Section 194LA of the Income-tax Act did not require deduction for agricultural land and that the later proviso and CBDT circular only clarified the statutory exemption. Once the compensation was crystallised into a judgment debt, it had to be paid in full without deduction, and any amount already deducted was to be redeposited for disbursement to the claimants.
Compensation awarded under an arbitral award made under Section 3G(5) of the National Highways Act, 1956 was stated to be exempt from TDS in view of Section 96 of the 2013 Land Acquisition Act, which the Court treated as applicable to post-enactment compensation, including acquisitions under the National Highways Act. It further noted that Section 194LA of the Income-tax Act did not require deduction for agricultural land and that the later proviso and CBDT circular only clarified the statutory exemption. Once the compensation was crystallised into a judgment debt, it had to be paid in full without deduction, and any amount already deducted was to be redeposited for disbursement to the claimants.
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