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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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Taxability of receipts reported in Form 26AS depends on the real nature of the underlying transaction, not solely on the deductor's description of them as commission. Form 26AS reflects deductor-reported TDS information and is not conclusive of the recipient's taxable income. Invoice-wise reconciliation of recharge-voucher purchases and sales may establish that the difference between reported receipts and declared commission represents trade discount. Where the Revenue produces no material disproving that reconciliation or showing the discount to be fictitious, trade discount cannot be assessed as commission income merely because it is reported as such in Form 26AS.
Taxability of receipts reported in Form 26AS depends on the real nature of the underlying transaction, not solely on the deductor's description of them as commission. Form 26AS reflects deductor-reported TDS information and is not conclusive of the recipient's taxable income. Invoice-wise reconciliation of recharge-voucher purchases and sales may establish that the difference between reported receipts and declared commission represents trade discount. Where the Revenue produces no material disproving that reconciliation or showing the discount to be fictitious, trade discount cannot be assessed as commission income merely because it is reported as such in Form 26AS.
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