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...
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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