Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Tax deducted at source that is subsequently deposited into the Government Treasury should not remain recoverable as principal TDS liability once the remittance is verified. Interest for delayed remittance continues to apply, but only up to the actual date of deposit; challans, payment dates and correlation with the demand require verification before recomputation. Renewable Energy Certificate registration charges require examination of the payment's nature, recipient, supporting invoice or demand, and statutory basis. Where the charges qualify as statutory or registration fees not subject to TDS, the related demand and interest should be deleted; otherwise, liability must be determined under the applicable law.
Tax deducted at source that is subsequently deposited into the Government Treasury should not remain recoverable as principal TDS liability once the remittance is verified. Interest for delayed remittance continues to apply, but only up to the actual date of deposit; challans, payment dates and correlation with the demand require verification before recomputation. Renewable Energy Certificate registration charges require examination of the payment's nature, recipient, supporting invoice or demand, and statutory basis. Where the charges qualify as statutory or registration fees not subject to TDS, the related demand and interest should be deleted; otherwise, liability must be determined under the applicable law.
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