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...
Payments to non-residents for travel-agent and hotel-booking commissions did not attract TDS on the facts found, because the assessee had furnished Form 15CB for each transaction, deducted and deposited tax wherever applicable, and filed the TDS returns. The HC accepted the Tribunal's finding that the commission payments to banks, credit card companies, travel agents and related service providers were not sums liable for deduction under section 195 in those circumstances. Since the assessee had complied with the TDS requirements and there was no adverse reporting in Form 3CD on non-deduction, it could not be treated as an assessee in default under section 201, and the deletion of section 201(1) and 201(1A) action was upheld.
Payments to non-residents for travel-agent and hotel-booking commissions did not attract TDS on the facts found, because the assessee had furnished Form 15CB for each transaction, deducted and deposited tax wherever applicable, and filed the TDS returns. The HC accepted the Tribunal's finding that the commission payments to banks, credit card companies, travel agents and related service providers were not sums liable for deduction under section 195 in those circumstances. Since the assessee had complied with the TDS requirements and there was no adverse reporting in Form 3CD on non-deduction, it could not be treated as an assessee in default under section 201, and the deletion of section 201(1) and 201(1A) action was upheld.
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