Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 206AA read with Rule 114AAA(3) applied where the seller's PAN was inoperative on the date of property purchase because it was not linked with Aadhaar, so higher TDS was prima facie attracted. However, the Tribunal held that the buyer should not bear higher TDS if evidence shows the seller disclosed the transaction in her return and paid due taxes, following the principle underlying section 40(a)(ia) and section 201(1). The demand was therefore not finally sustained and the matter was remitted for de novo verification of the seller's tax disclosure and payment.
Section 206AA read with Rule 114AAA(3) applied where the seller's PAN was inoperative on the date of property purchase because it was not linked with Aadhaar, so higher TDS was prima facie attracted. However, the Tribunal held that the buyer should not bear higher TDS if evidence shows the seller disclosed the transaction in her return and paid due taxes, following the principle underlying section 40(a)(ia) and section 201(1). The demand was therefore not finally sustained and the matter was remitted for de novo verification of the seller's tax disclosure and payment.
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