Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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TDS credit on rental income from jointly owned property is ordinarily governed by section 199 and rule 37BA, which provide credit to the deductee and require prescribed declarations and reporting for transfer to another person assessable on the income. Where the entire TDS was deducted and reported against one co-owner's PAN, no transfer declaration was furnished, and the other co-owners neither claimed credit nor objected to that co-owner's claim, the entire credit should be allowed to that co-owner. Procedural requirements cannot permit the Revenue to retain TDS where no other person seeks the unclaimed credit.
TDS credit on rental income from jointly owned property is ordinarily governed by section 199 and rule 37BA, which provide credit to the deductee and require prescribed declarations and reporting for transfer to another person assessable on the income. Where the entire TDS was deducted and reported against one co-owner's PAN, no transfer declaration was furnished, and the other co-owners neither claimed credit nor objected to that co-owner's claim, the entire credit should be allowed to that co-owner. Procedural requirements cannot permit the Revenue to retain TDS where no other person seeks the unclaimed credit.
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