Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Interest merged into a decree and payable in execution retains the character of a judgment debt, so the judgment debtor cannot deduct tax at source from the decretal interest unless the decree itself authorises such deduction. The court applied the principle that a decree must be executed as it stands, subject only to adjustments permitted under the Civil Procedure Code, and held that section 195 did not extend to a decretal debt. The deduction already made toward TDS was therefore upheld, and the challenge failed.
Interest merged into a decree and payable in execution retains the character of a judgment debt, so the judgment debtor cannot deduct tax at source from the decretal interest unless the decree itself authorises such deduction. The court applied the principle that a decree must be executed as it stands, subject only to adjustments permitted under the Civil Procedure Code, and held that section 195 did not extend to a decretal debt. The deduction already made toward TDS was therefore upheld, and the challenge failed.
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