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...
Binding interim High Court directions treating Leave Travel Concession reimbursements as non-income for TDS purposes prevented bank branches from being treated as assessees in default for non-deduction on reimbursements involving foreign travel. Section 201 liability arises only where tax was not deducted despite a subsisting legal obligation. Compliance with operative interim directions eclipsed that obligation for the relevant period, even though employees remained liable if the writ petition failed. A subsequent merits decision on the exemption issue could not retrospectively impose default liability. Consequently, demands for default and related interest were set aside.
Binding interim High Court directions treating Leave Travel Concession reimbursements as non-income for TDS purposes prevented bank branches from being treated as assessees in default for non-deduction on reimbursements involving foreign travel. Section 201 liability arises only where tax was not deducted despite a subsisting legal obligation. Compliance with operative interim directions eclipsed that obligation for the relevant period, even though employees remained liable if the writ petition failed. A subsequent merits decision on the exemption issue could not retrospectively impose default liability. Consequently, demands for default and related interest were set aside.
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