Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 194N places the obligation to deduct tax at source on the banking company making a cash payment, not on the customer withdrawing cash. Failure to deduct attracts the statutory consequence under section 271C against the person responsible for deduction. A bank cannot impose a lien on a customer's current account for an alleged TDS liability without statutory authority or a direction from the income-tax authorities. The lien was directed to be released and account operations permitted after the customer furnished income-tax returns for the relevant three consecutive years, without limiting lawful action by tax authorities.
Section 194N places the obligation to deduct tax at source on the banking company making a cash payment, not on the customer withdrawing cash. Failure to deduct attracts the statutory consequence under section 271C against the person responsible for deduction. A bank cannot impose a lien on a customer's current account for an alleged TDS liability without statutory authority or a direction from the income-tax authorities. The lien was directed to be released and account operations permitted after the customer furnished income-tax returns for the relevant three consecutive years, without limiting lawful action by tax authorities.
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