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...
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Tax deduction on transfer of agricultural land under section 194-IA does not arise unless the land falls within that provision's scope. The text states that a registered sale deed identified the property as agricultural land and no contrary material established that it was covered land; therefore, no primary TDS obligation applied. Section 206AA only increases the deduction rate where tax is otherwise deductible and PAN is not furnished; it cannot independently create a TDS liability. Consequently, section 201(1) cannot treat the purchaser as an assessee in default absent a statutory duty to deduct. The short-deduction demand and consequential interest were deleted.
Tax deduction on transfer of agricultural land under section 194-IA does not arise unless the land falls within that provision's scope. The text states that a registered sale deed identified the property as agricultural land and no contrary material established that it was covered land; therefore, no primary TDS obligation applied. Section 206AA only increases the deduction rate where tax is otherwise deductible and PAN is not furnished; it cannot independently create a TDS liability. Consequently, section 201(1) cannot treat the purchaser as an assessee in default absent a statutory duty to deduct. The short-deduction demand and consequential interest were deleted.
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