Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Delay in filing the first appeal was held condonable where the assessee had been pursuing rectification before CPC and filed the appeal only after that remedy failed; dismissal as time-barred was not justified. On merits, salary slips, Form 16 and bank statements showed tax had been deducted from salary and only net salary was paid, so the employee could not be denied TDS credit merely because the employer failed to deposit the tax. The Assessing Officer was directed to verify the deduction and allow the corresponding credit.
Delay in filing the first appeal was held condonable where the assessee had been pursuing rectification before CPC and filed the appeal only after that remedy failed; dismissal as time-barred was not justified. On merits, salary slips, Form 16 and bank statements showed tax had been deducted from salary and only net salary was paid, so the employee could not be denied TDS credit merely because the employer failed to deposit the tax. The Assessing Officer was directed to verify the deduction and allow the corresponding credit.
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