Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
TDS credit transferred following amalgamation must be granted to the amalgamated entity where the related income is substantively assessed in its hands and the amalgamating entity has not claimed that credit. Section 199 read with Rule 37BA applies despite the TDS appearing under the amalgamating entity's PAN. Where the credit was claimed in the original and revised returns and subsequently allowed, refund interest under section 244A(1) is payable for the full applicable period. Delay cannot be excluded under section 244A(2) merely because the Assessing Officer wrongly attributes default to the taxpayer.
TDS credit transferred following amalgamation must be granted to the amalgamated entity where the related income is substantively assessed in its hands and the amalgamating entity has not claimed that credit. Section 199 read with Rule 37BA applies despite the TDS appearing under the amalgamating entity's PAN. Where the credit was claimed in the original and revised returns and subsequently allowed, refund interest under section 244A(1) is payable for the full applicable period. Delay cannot be excluded under section 244A(2) merely because the Assessing Officer wrongly attributes default to the taxpayer.
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