Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The article notes that the ITAT treated a bank as not being an assessee in default for failure to deduct tax at source on Leave Travel Concession reimbursement during the period covered by subsisting Madras High Court interim directions. It records that compliance with that operative judicial direction meant the bank's non-deduction could not attract liability under section 201/201(1A), and the resulting demand was unsustainable. The same approach was applied to the connected appeals on the same controversy.
The article notes that the ITAT treated a bank as not being an assessee in default for failure to deduct tax at source on Leave Travel Concession reimbursement during the period covered by subsisting Madras High Court interim directions. It records that compliance with that operative judicial direction meant the bank's non-deduction could not attract liability under section 201/201(1A), and the resulting demand was unsustainable. The same approach was applied to the connected appeals on the same controversy.
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