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...
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
Common area maintenance charges paid under separate service arrangements were treated as contractual payments, not rent, because they did not represent consideration for use of land, building or premises. The Tribunal followed its earlier co-ordinate Bench view and held that TDS was correctly deducted under section 194C on maintenance services, not under section 194I. The Revenue's short-deduction demand under sections 201(1) and 201(1A) therefore did not survive, and the relief granted by the CIT(A) was upheld for all three assessment years.
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